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3,739 results for “transfer pricing”+ Section 131clear

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Key Topics

Section 143(3)70Addition to Income62Section 6844Section 143(2)30Section 14829Section 69A28Section 14724Section 25022Section 14A22Disallowance

GOLDMAN SACHS (INDIA) SECURITIES PVT LTD,MUMBAI vs. ADDL.C.I.T. RG.3(1), MUMBAI

In the result, appeal stands partly allowed

ITA 6912/MUM/2012[2008-09]Status: DisposedITAT Mumbai22 Jul 2016AY 2008-09

Bench: Shri Saktijit Dey & Shri Ashwani Taneja

For Appellant: Shri P.J. Pardiwala, Sr. CounselFor Respondent: Shri N.K. Chand
Section 143(3)Section 144C(13)Section 92C(2)

section 10A of the Act. 8. Without prejudice to the above ground, the learned AU erred in reducing the telecommunication charges only from the export turnover and not from both, i.e total turnover and export turnover, in computing the deduction u/s 10A of the Act. 9. The Appellant craves leave to add, alter, vary, omit, substitute or amend

(Now known as Sony India Limited)

Showing 1–20 of 3,739 · Page 1 of 187

...
21
Transfer Pricing12
Exemption12
ITA/16/2014
HC Delhi
16 Mar 2015

Sections (1) and (2) to Section 92C are applicable to the assessed, as well as the Assessing Officer invoking power under Sub-Section (3) to Section 92C of the Act. As noted above, sub-section (2) to Section 92C stipulates that most appropriate method, out of the methods specified in sub-section (1) shall be applied to determine

VIACOM 18 MEDIA P.LTD,MUMBAI vs. ADDL CIT 11(1), MUMBAI

In the result, assessee‟s appeal for A

ITA 8754/MUM/2010[2006-07]Status: DisposedITAT Mumbai03 Sept 2021AY 2006-07

Bench: Shri C.N. Prasad & Shri S. Rifaur Rahman

131 (Mum. Trib.). 109. The learned Departmental Representative relied upon the order of the authorities below and submitted that the non–charging of interest to non–A.E. are irrelevant. The undue advantage passed on to the A.E. is not acceptable and the Transfer Pricing provision is applicable. 47 Viacom 18 Media Pvt. Ltd. 110. Considered the rival submissions and perused

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

ITA 2003/MUM/2023[2017-18]Status: DisposedITAT Mumbai29 Nov 2023AY 2017-18

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

For Appellant: Shri Devendra Jain &For Respondent: Shri Vivek Perumpura
Section 131Section 143Section 147Section 148Section 263Section 271BSection 68Section 92C

transfer-pricing officer to compute the arm‟s- length price of the international transaction on 30/12/2019. The learned TPO passed an order under section 92CA (3) of the Act dated 27/1/2021 stating that the value of the international transaction with its associated enterprises are not being disturbed, since assessee has not filed 3CEB report. Penalty proceedings were initiated under section

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

ITA 2002/MUM/2023[2012-13]Status: DisposedITAT Mumbai29 Nov 2023AY 2012-13

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

For Appellant: Shri Devendra Jain &For Respondent: Shri Vivek Perumpura
Section 131Section 143Section 147Section 148Section 263Section 271BSection 68Section 92C

transfer-pricing officer to compute the arm‟s- length price of the international transaction on 30/12/2019. The learned TPO passed an order under section 92CA (3) of the Act dated 27/1/2021 stating that the value of the international transaction with its associated enterprises are not being disturbed, since assessee has not filed 3CEB report. Penalty proceedings were initiated under section

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

ITA 2004/MUM/2023[2018-19]Status: DisposedITAT Mumbai29 Nov 2023AY 2018-19

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

For Appellant: Shri Devendra Jain &For Respondent: Shri Vivek Perumpura
Section 131Section 143Section 147Section 148Section 263Section 271BSection 68Section 92C

transfer-pricing officer to compute the arm‟s- length price of the international transaction on 30/12/2019. The learned TPO passed an order under section 92CA (3) of the Act dated 27/1/2021 stating that the value of the international transaction with its associated enterprises are not being disturbed, since assessee has not filed 3CEB report. Penalty proceedings were initiated under section

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

ITA 2005/MUM/2023[2019-20]Status: DisposedITAT Mumbai29 Nov 2023AY 2019-20

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

For Appellant: Shri Devendra Jain &For Respondent: Shri Vivek Perumpura
Section 131Section 143Section 147Section 148Section 263Section 271BSection 68Section 92C

transfer-pricing officer to compute the arm‟s- length price of the international transaction on 30/12/2019. The learned TPO passed an order under section 92CA (3) of the Act dated 27/1/2021 stating that the value of the international transaction with its associated enterprises are not being disturbed, since assessee has not filed 3CEB report. Penalty proceedings were initiated under section

M/S CAE FLIGHT TRAINING (INDIA) PRIVATE LIMITED,BANGALORE vs. ITO, BANGALORE

In the result, Both the C

ITA 84/BANG/2015[2010-11]Status: DisposedITAT Bangalore25 Jul 2019AY 2010-11

Bench: Shri Arun Kumar Garodia & Smt. Beena Pillai

Section 36 (1) (iii) of the IT Act was never the issue under consideration. Similarly, the case of Narendra Kumar Maheshwari was also in the context of role of the Controller of Capital Issues (CCI) in giving sanction for the issue of debentures and on the larger issue of principles of comity of courts administering the laws throughout the country

ITO, BANGALORE vs. M/S CAE FLIGHT TRAINING PVT. LTD.,, BANGALORE

In the result, Both the C

ITA 63/BANG/2015[2010-11]Status: DisposedITAT Bangalore25 Jul 2019AY 2010-11

Bench: Shri Arun Kumar Garodia & Smt. Beena Pillai

Section 36 (1) (iii) of the IT Act was never the issue under consideration. Similarly, the case of Narendra Kumar Maheshwari was also in the context of role of the Controller of Capital Issues (CCI) in giving sanction for the issue of debentures and on the larger issue of principles of comity of courts administering the laws throughout the country

M/S INSTRUMENTARIUM CORPORATION LTD.,KOLKATA vs. DDIT (IT)-1(1), KOLKATA, KOLKATA

ITA 1549/KOL/2009[2004-05]Status: DisposedITAT Kolkata15 Jul 2016AY 2004-05

Bench: The Special Bench:

transfer pricing provisions in India, and the CBDT circular no. 14 of 2001 (supra). In particular, our attention is invited to the observation that “the I.T.A. Nos.1548 and 1549/Kol/2009 Assessment years: 2003-04 and 2004-05 Page 14 of 41 new Section 92 is, therefore, not intended to be applied in the cases where adoption of the arm’s length

YOUNG INDIAN,NEW DELHI vs. ADDL. CIT (INV.), NEW DELHI

In the result, the appeal filed by the assessee is dismissed

ITA 5303/DEL/2016[2011-12]Status: DisposedITAT Delhi30 Aug 2018AY 2011-12

Bench: Shri R. K. Panda & Ms. Suchitra Kambleassessment Year : 2011-12 Young Indian, Addl. Dit (Inv.), Unit- 4, 5A, Herald House, New Delhi. Bahadur Shah Zafar Marg, Vs. New Delhi.

For Appellant: Shri Yogesh Thar, CA
Section 131Section 133(6)Section 138

transfer of such shares, the method of arriving at the fair price of such shares by M/s Young Indian in accordance with the terms of clause 4.11 of the Articles of Association of M/s Young Indian and the fair price so determined or determinable. Also provide the details of payments received by M/s Young Indian from the incoming members

DCIT, CIRCLE - 11(1), KOLKATA, KOLKATA vs. M/S. J. J. EXPORTERS LTD., KOLKATA

ITA 1371/KOL/2017[2008-09]Status: DisposedITAT Kolkata19 Sept 2018AY 2008-09

Bench: Shri A. T. Varkey, Jm & Dr. A. L. Saini, Am]

Section 92C

Section 92F(ii) lays down that "'arm's length price” means a price which is applied or proposed to be applied in a transaction between persons other than associated enterprises, in uncontrolled conditions." Sec.92(v) defines “transaction” to include "an arrangement, undertaking or action in concert,- (A) whether or not such arrangement, understanding or action is formal or in writing

DCIT, CIRCLE - 11(1), KOLKATA, KOLKATA vs. M/S. J. J. EXPORTERS LTD., KOLKATA

ITA 1372/KOL/2017[2009-10]Status: DisposedITAT Kolkata19 Sept 2018AY 2009-10

Bench: Shri A. T. Varkey, Jm & Dr. A. L. Saini, Am]

Section 92C

Section 92F(ii) lays down that "'arm's length price” means a price which is applied or proposed to be applied in a transaction between persons other than associated enterprises, in uncontrolled conditions." Sec.92(v) defines “transaction” to include "an arrangement, undertaking or action in concert,- (A) whether or not such arrangement, understanding or action is formal or in writing

HAPAG LLOYD INDIA P. LTD,MUMBAI vs. DCIT 7(1)(2), MUMBAI

In the result, appeals are allowed in terms indicated above

ITA 819/MUM/2019[2008-09]Status: DisposedITAT Mumbai27 Sept 2019AY 2008-09

Bench: Shri Saktijit Dey & Shri Manoj Kumar Aggarwal

For Appellant: Shri Rajan Vora a/wFor Respondent: Shri Jayant Kumar
Section 143(3)Section 144C(13)Section 153Section 92C

section 144C(13) of the Act. 15. The learned Counsel for the assessee submitted, in the first round of litigation, when the very same issue came up for consideration before the Tribunal, the Tribunal categorically held that the price charged by GESA under the sub–agency agreement cannot be treated as internal CUP. He submitted, though, the Transfer Pricing Officer

RANBAXY LABORATORIES LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, we direct the AO to reduce the book profit u/s 115JB of the Act by the amount of reversal of the provision of Rs

ITA 196/DEL/2013[2008-09]Status: DisposedITAT Delhi25 Apr 2016AY 2008-09

Bench: Sh. I. C.Sudhir Judicialmember & Sh. Prashant Maharishia.Y.: - 2008-09 Ranbaxy Laboratories Ltd. Vs Acit 12Th Floor, Devika Tower, Range -15 6, Nehru Place New Delhi New Delhi Pan No. Aaacr0127N (Appellant) (Respondent)

For Appellant: 1. Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Amrendra Kumar, CIT, DR
Section 143Section 143(3)Section 92D

Section (2) to Section 14A of the Act and sub Rule (1) to Rule 8D of the Rules. 14. The view and legal ratio expressed above is not being elucidated for the first time. The Delhi High Court in Maxopp Investment Ltd. v. CIT [2012] 347 ITR 272/203 Taxman 364/15 taxmann.com 390 has observed:- 'Scope of sub-sections

ACCC 30, MUMBAI vs. UNITED SHIPPERS LTD, MUMBAI

In the result, appeal filed by the assessee is partly allowed and appeal filed by the AO is dismissed

ITA 3036/MUM/2012[2007-08]Status: DisposedITAT Mumbai26 Apr 2022AY 2007-08

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm The Asst. Commissioner Of United Shippers Ltd. United India Bldg, 2N D Floor, Sir Income-Tax, Circle-30 R.No. 403, 4Th Floor, P.M. Road , Vs. Aayakar Bhavan, M.K. Marg, Fort, Mumbai-400 020 Mumbai-400 001 (Appellant) (Respondent) Pan No. Aaacu0764C The Asst. Commissioner Of United Shippers Ltd. Income-Tax, Circle-30 United India Bldg, 2N D Floor, Sir R.No. 403, 4Th Floor, P.M. Road , Vs. Ayakar Bhavan, Fort, M.K. Marg, Mumbai-400 001 Mumbai-400 020 (Appellant) (Respondent)

For Appellant: Shri Madhur Agarwal, AdvocateFor Respondent: Shri Ms. Vatsalaa Jha, CIT DR
Section 14ASection 92Section 92CSection 92C(3)

Section 92C (2) of the act. With respect to the arm’s-length price of the corporate guarantee, he following the decision of his predecessor in earlier assessment year held that corporate guarantee fees of 0.5% charged to its associated enterprise based on the past action of the learned transfer-pricing officer, it is at arm’s-length. Therefore

O.C TANNER INDIA PRIVATE LIMITED ,MUMBAI vs. DCIT, CIRCLE -2(3)(1), MUMBAI

In the result the appeal is, accordingly, he appeal is, accordingly, allowed for statistical allowed for statistical purposes

ITA 5785/MUM/2024[2021-22]Status: DisposedITAT Mumbai24 Jul 2025AY 2021-22

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2021-22 O.C. Tanner India Pvt. Ltd., Dy. Cit, Circle-2(3)(1), No. 2, Lave 7 Tower 2, Phase Ii, 552, 5Th Floor, Aayakar Bhavan, Raiaskaran Techpark Andheri Vs. Maharishi Karve Road, Kurla Road, Andheri East, Mumbai-400020. Sakinaka S.O. Mumbai, Mumbai-400072. Pan No. Aabco 1031 F Appellant Respondent

For Appellant: Mr. Vijay Mehta, CA
Section 144C(13)Section 144C(5)

section 144C(13), upholding the transfer pricing adjustments in full. The additions made in the final assessment are as under: The additions made in the final assessment are as under: The additions made in the final assessment are as under: S. No. Particulars Particulars Amount (INR) Amount (INR) 1 Income as per return Income as per return Nil 2 Unabsorbed

SUN PHARMACEUTICALS INDUSTRIES LTD. ( ERSTWHILE RANBAXY LABORATORIES LIMITED),BARODA vs. THE ACIT,CENT.CIRCLE-1, BARODA

ITA 702/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad08 Apr 2021AY 2011-12
For Appellant: Shri S.N. Soparkar, Sr. A.RFor Respondent: Shri Mohd Usman, CIT-D.R
Section 115JSection 143(2)Section 143(3)Section 144CSection 144C(5)Section 37(1)Section 92C

prices from 80IB/IC units to the company. xi. Why not after excluding other income like royalty, technological r-license income, export incentives, misc. Income, and sundries etc. which are not eligible for 80IB/IC deduction, the determination of eligible profits is done, xii. The company does trading activity also. Why the trading profit should not be excluded for determining eligible income

M/S TYCO ELECTRONICS SYSTEMS INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal being IT(TP)A No

ITA 1251/BANG/2011[2007-08]Status: DisposedITAT Bangalore19 Feb 2020AY 2007-08

Bench: Shri N.V.Vasudevan & Shri A.K.Garodia

For Appellant: Shri Sumeet Khurana, CAFor Respondent: Ms.Neera Malhotra, CIT-DR
Section 143(3)

section 143(1) of the Act to the company. 37. The assessee has filed an application dated 27-06-2019 for admission of the following additional ground; IT(TP)A No.1350 & 1251(B)/201 21 “The ld.TPO and the ld.DRP failed to appreciate the difference in rates of depreciation adopted by the appellant and the comparable companies as selected

M/S. NATUREX INDIA PVT. LTD,MUMBAI vs. NFAC, DELHI DCIT-CIR 2(3) (1), MUMBAI

In the result, appeal of the assessee is allowed for statistical purposes

ITA 540/MUM/2022[2017-18]Status: DisposedITAT Mumbai08 May 2024AY 2017-18

Bench: Shri Vikas Awasthy & Shri Gagan Goyalm/S. Naturex India Pvt. Ltd. 502, 5Th Floor, Akruti Centre Point, Midc Central Road, Andheri (East), Chakala Midc S.O. Mumbai-400093 Pan: Aabcv0883A ..... Appellant Vs. Nfac, Delhi/Dcit Cir. 2(3) (1) Aayakar Bhavan, M. K. Road, Mumbai- 400 020 ..... Respondent

For Appellant: Shri Aliasger Rampurawala, Shri AmolFor Respondent: Shri Kiran Unavekar, Ld. DR
Section 143(3)Section 144C(13)Section 92

Transfer Pricing Officer may, for the purposes of determining the arm's length price under this section, exercise all or any of the powers specified in clauses (a) to (d) of sub-section (1) of section 131