TRANSUNION INTERNATIONAL INC.,MUMBAI vs. DEPUTY COMM. OF INCOME TAX (INTERNATIONAL TAXATION)-4(1)(2), MUMBAI

Appeal of the assessee is allowed

Bench: Shri Pawan Singh, Jm & Ms Padmavathy S, Am

Transfer Pricing Officers tend to take a conservative view. The correction of such view take very long time with the existing appellate structure. With a view to provide speedy disposal, it is proposed to amend the Income- tax Act so as to create an alternative dispute resolution mechanism within the income-tax department and accordingly, section 144C has been proposed

LANXESS INDIA P.LTD,THANE vs. ASST CIT CIR 1, THANE

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2009-10 Lanxess India Private Limited, Asst. Commissioner Of Income-Tax, Lanxess House, Plot No. 162-164, Circle 1, Road No. 27, Wagle Estate, Opp. Iti Vs. 6Th Floor, Asher It Park, Road No. College, Midc, 16-Z, Wagle Industrial Estate, Thane-(West)-400604. Thane. Pan No. Aaccb 3880 A Appellant Respondent Assessment Year: 2009-10 Asst. Commissioner Of Income-Tax, Lanxess India Private Limited, Circle 1, Lanxess House, Plot No. 162-164, 6Th Floor, Asher It Park, Road No. 16- Vs. Road No. 27, Wagle Estate, Opp. Iti Z, Wagle Industrial Estate, College, Midc, Thane. Thane-(West)-400604 Pan No. Aaccb 3880 A Appellant Respondent

13) of the Act are void ab initio void ab initio, because provisions of section 144C are applicable only from assessment year provisions of section 144C are applicable only from assessment year provisions of section 144C are applicable only from assessment year 2010-11 and onwards. He submitted that in view of non 11 and onwards. He submitted that

ACIT CIR 1, THANE vs. LANXESS INDIA P.LTD, THANE

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2009-10 Lanxess India Private Limited, Asst. Commissioner Of Income-Tax, Lanxess House, Plot No. 162-164, Circle 1, Road No. 27, Wagle Estate, Opp. Iti Vs. 6Th Floor, Asher It Park, Road No. College, Midc, 16-Z, Wagle Industrial Estate, Thane-(West)-400604. Thane. Pan No. Aaccb 3880 A Appellant Respondent Assessment Year: 2009-10 Asst. Commissioner Of Income-Tax, Lanxess India Private Limited, Circle 1, Lanxess House, Plot No. 162-164, 6Th Floor, Asher It Park, Road No. 16- Vs. Road No. 27, Wagle Estate, Opp. Iti Z, Wagle Industrial Estate, College, Midc, Thane. Thane-(West)-400604 Pan No. Aaccb 3880 A Appellant Respondent

13) of the Act are void ab initio void ab initio, because provisions of section 144C are applicable only from assessment year provisions of section 144C are applicable only from assessment year provisions of section 144C are applicable only from assessment year 2010-11 and onwards. He submitted that in view of non 11 and onwards. He submitted that

FIRMENICH AROMATICS (INDIA) P. LTD,MUMBAI vs. DCIT 9(3)(1), MUMBAI

In the result, assessee’s appeal is partly allowed

Bench: Shri Saktijit Dey & Shri Rajesh Kumar

section 144C(13) of the Income Tax Act, 1961 (for short “the Act”) for the assessment year 2012–13 in pursuance to the directions of the Dispute Resolution Panel (DRP). 2. The assessee has raised five grounds. 3. At the outset, the learned Authorised Representative on the instructions of the assessee did not want to press grounds no.3

ACCENTURE SERVICES P.LTD,MUMBAI vs. ADDL CIT RG 3(1), MUMBAI

In the result, assessee’s appeal is partly allowed

Bench: Shri Saktijit Dey & Shri Rajesh Kumar

144C of the Income Tax Act, 1961 (for short “the Act”) for the assessment year 2008–09, in pursuance to the directions of the Dispute Resolution Panel–I (DRP), Mumbai. 2. Brief facts are, the assessee an Indian Company is a subsidiary of M/s. Beaumont Development Centre Holding Ltd. and part of the Accenture Group. The assessee is basically providing

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

In the result, appeal stands partly allowed

Bench: Shri Saktijit Dey & Shri Ashwani Taneja

section 144C(13) of the Income-tax Act, 1961 ('Act'), the Appellant respectfully submits that the learned A0 erred in passing the order on the following grounds: 1. In making an upward transfer pricing

BARCLAYS BANK PLC,MUMBAI vs. CIT (INTERNATIONAL TAXATION)-RANGE-1, MUMBAI

In the result, the appeal by the assessee stands partly allowed

Bench: Shri Shamim Yahya (Am) & Shri Amarjit Singh (Jm)

transfer pricing adjustment were made by the TPO. These have been detailed in the assessment order para ‘7’ of the assessment order referred above. The TP adjustment made by TPO were in total Rs. 83,045,395/-. Assessee had made objection before the DRP and pursuant to DRP direction, the assessment was framed as per section 144C(13

TATA AIG GENERAL INSURANCE COMAPANY LTD,MUMBAI vs. ASST CIT 2(3), MUMBAI

In the result, the appeal of the assessee is allowed

Transfer Pricing. After an international transaction is noticed subject to satisfaction of section 92B, a reference is made to the TPO under sub-Section (1) of Section 92CA of the Act. The TPO after considering the documents submitted by the assessee is to pass an order under Section 92CA (3) of the Act. As per Section 92CA (3A), the order