ZENZI PHARMACEUTICAL INDUSTIES PVT LTD.,MUMBAI CITY vs. CIT (TRANSFER PRICING)-4, MUMBAI CITY

In the result all the four appeals filed by the assessee are dismissed

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

reopened by issuing notice under section 148 of the act and reference was made to the learned transfer pricing officer in terms of Para number 3.3 of the instruction number 3/2016 and survey findings were also shared ITA No. 2002-05/Mum/2023 A.Y. 2012-13, 17-18, 18-19, 19-20 ZENZI PHARMECEUTICAL INDUSTRIES PVT. Ltd. with the transfer pricing

ZENZI PHARMACEUTICAL INDUSTIES PVT LTD.,MUMBAI vs. CIT (TRANSFER PRICING)-4, MUMBAI

In the result all the four appeals filed by the assessee are dismissed

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

reopened by issuing notice under section 148 of the act and reference was made to the learned transfer pricing officer in terms of Para number 3.3 of the instruction number 3/2016 and survey findings were also shared ITA No. 2002-05/Mum/2023 A.Y. 2012-13, 17-18, 18-19, 19-20 ZENZI PHARMECEUTICAL INDUSTRIES PVT. Ltd. with the transfer pricing

ZENZI PHARMACEUTICAL INDUSTIES PVT LTD.,MUMBAI CITY vs. CIT (TRANSFER PRICING)-4, MUMBAI CITY

In the result all the four appeals filed by the assessee are dismissed

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

reopened by issuing notice under section 148 of the act and reference was made to the learned transfer pricing officer in terms of Para number 3.3 of the instruction number 3/2016 and survey findings were also shared ITA No. 2002-05/Mum/2023 A.Y. 2012-13, 17-18, 18-19, 19-20 ZENZI PHARMECEUTICAL INDUSTRIES PVT. Ltd. with the transfer pricing

ZENZI PHARMACEUTICAL INDUSTIES PVT LTD.,MUMBAI vs. CIT (TRANSFER PRICING)-4, MUMBAI

In the result all the four appeals filed by the assessee are dismissed

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

reopened by issuing notice under section 148 of the act and reference was made to the learned transfer pricing officer in terms of Para number 3.3 of the instruction number 3/2016 and survey findings were also shared ITA No. 2002-05/Mum/2023 A.Y. 2012-13, 17-18, 18-19, 19-20 ZENZI PHARMECEUTICAL INDUSTRIES PVT. Ltd. with the transfer pricing

VODAFONE INDIA LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX-8(3)(2), MUMBAI

transferring pre-paid talk time and connections and\naccordingly the discount extended was not income earned by the\ndistributors.\n7.2. In the Draft Assessment Order, dated 31/03/2015, the Assessing\nOfficer proposed disallowance under Section 40(a)(ia) of the Act\non the upfront discount extended to the pre-paid distributors by\nterming the arrangement as 'Principal to Agent instead

DCIT CC 4 (4), MUMBAI, MUMBAI vs. SANMAN TRADE IMPEX LIMITED, MUMBAI

In the result, appeals of the Revenue are dismissed dismissed whereas appeals of the assessee are partly allowed appeals of the assessee are partly allowed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

reopening of the assessment and therefore, contention of the contention of the assessee are liable to be rejected assessee are liable to be rejected. 12.3 We have heard rival submission o We have heard rival submission of the parties and perused the f the parties and perused the relevant material on record. In our opinion, the contention raised by relevant

SANMAN TRADE IMPEX LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX-CENTRAL CIRCLE 4(4), MUMBAI, MUMBAI

In the result, appeals of the Revenue are dismissed dismissed whereas appeals of the assessee are partly allowed appeals of the assessee are partly allowed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

reopening of the assessment and therefore, contention of the contention of the assessee are liable to be rejected assessee are liable to be rejected. 12.3 We have heard rival submission o We have heard rival submission of the parties and perused the f the parties and perused the relevant material on record. In our opinion, the contention raised by relevant

DCIT CC 4 (4), MUMBAI, MUMBAI vs. SANMAN TRADE IMPEX LIMITED, MUMBAI

In the result, appeals of the Revenue are dismissed dismissed whereas appeals of the assessee are partly allowed appeals of the assessee are partly allowed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

reopening of the assessment and therefore, contention of the contention of the assessee are liable to be rejected assessee are liable to be rejected. 12.3 We have heard rival submission o We have heard rival submission of the parties and perused the f the parties and perused the relevant material on record. In our opinion, the contention raised by relevant

DCIT CC 4(4), MUMBAI, MUMBAI vs. SANMAN TRADE IMPEX LIMITED, MUMBAI

In the result, appeals of the Revenue are dismissed dismissed whereas appeals of the assessee are partly allowed appeals of the assessee are partly allowed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

reopening of the assessment and therefore, contention of the contention of the assessee are liable to be rejected assessee are liable to be rejected. 12.3 We have heard rival submission o We have heard rival submission of the parties and perused the f the parties and perused the relevant material on record. In our opinion, the contention raised by relevant

SANMAN TRADE IMPEX LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX- CENTRAL CIRCLE 4(4), MUMBAI, MUMBAI

In the result, appeals of the Revenue are dismissed dismissed whereas appeals of the assessee are partly allowed appeals of the assessee are partly allowed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

reopening of the assessment and therefore, contention of the contention of the assessee are liable to be rejected assessee are liable to be rejected. 12.3 We have heard rival submission o We have heard rival submission of the parties and perused the f the parties and perused the relevant material on record. In our opinion, the contention raised by relevant

DCIT 8(3)(2), MUMBAI vs. M/S VODAFONE IDEA LIMITED (EARLIER KNOWN AS VODAFONE INDIA LIMITED WHICH NOW STANDS MERGED WITH IDEA CELLULAR LIMITED (ICL) AND CONSEQUENTLY KNOWN AS VODAFONE IDEA LIMITED), MUMBAI

transferring pre-paid talk time and connections and\naccordingly the discount extended was not income earned by the\ndistributors.\n7.2. In the Draft Assessment Order, dated 31/03/2015, the Assessing\nOfficer proposed disallowance under Section 40(a)(ia) of the Act\non the upfront discount extended to the pre-paid distributors by\nterming the arrangement as 'Principal to Agent instead