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3,146 results for “transfer pricing”+ Section 69clear

Sorted by relevance

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Key Topics

Addition to Income75Section 143(3)42Section 6937Section 13233Deduction32Section 153C31Section 139(1)31Search & Seizure29Disallowance22Transfer Pricing

(Now known as Sony India Limited)

ITA/16/2014HC Delhi16 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

PUBLICIS COMMUNICATIONS P. LTD,MUMBAI vs. DCIT CIR 7(3)(1), MUMBAI

In the result, for assessment year 2012 – 13, appeal of the assessee is allowed for statistical purposes whereas the cross objection of the assessing officer is dismissed

ITA 462/MUM/2016[2011-12]Status: DisposedITAT Mumbai27 Apr 2023AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

For Appellant: Shri Ketan VedFor Respondent: Shri Asif Karmali
Section 143(3)

Showing 1–20 of 3,146 · Page 1 of 158

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18
Section 69B16
Section 14716
Section 144C(13)
Section 144C(5)
Section 32(1)(ii)
Section 92C

Transfer Pricing Officer in this regard is misconceived, erroneous and incorrect. 3. Re : Disallowance of depreciation on goodwill: 3.1 The learned DCIT erred in disallowing depreciation on goodwill of ₹ 11,73,198 claimed by the Appellant under section 32(1)(ii) of the Act. 3.2 The learned DCIT erred in observing that once the asset is adjusted and removed from

PUBLICIS COMMUNICATIONS P.LTD,MUMBAI vs. DCIT CIR 7(1), MUMBAI

In the result, for assessment year 2012 – 13, appeal of the assessee is allowed for statistical purposes whereas the cross objection of the assessing officer is dismissed

ITA 1994/MUM/2014[2009-10]Status: DisposedITAT Mumbai27 Apr 2023AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

For Appellant: Shri Ketan VedFor Respondent: Shri Asif Karmali
Section 143(3)Section 144C(13)Section 144C(5)Section 32(1)(ii)Section 92C

Transfer Pricing Officer in this regard is misconceived, erroneous and incorrect. 3. Re : Disallowance of depreciation on goodwill: 3.1 The learned DCIT erred in disallowing depreciation on goodwill of ₹ 11,73,198 claimed by the Appellant under section 32(1)(ii) of the Act. 3.2 The learned DCIT erred in observing that once the asset is adjusted and removed from

PUBLICS COMMUNICATIONS P.LTD,MUMBAI vs. DCIT CIR 6(1), MUMBAI

In the result, for assessment year 2012 – 13, appeal of the assessee is allowed for statistical purposes whereas the cross objection of the assessing officer is dismissed

ITA 7523/MUM/2016[2010-11]Status: DisposedITAT Mumbai27 Apr 2023AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

For Appellant: Shri Ketan VedFor Respondent: Shri Asif Karmali
Section 143(3)Section 144C(13)Section 144C(5)Section 32(1)(ii)Section 92C

Transfer Pricing Officer in this regard is misconceived, erroneous and incorrect. 3. Re : Disallowance of depreciation on goodwill: 3.1 The learned DCIT erred in disallowing depreciation on goodwill of ₹ 11,73,198 claimed by the Appellant under section 32(1)(ii) of the Act. 3.2 The learned DCIT erred in observing that once the asset is adjusted and removed from

ZYDUS LIFESCIENCES LIMITED (FORMERLY KNOWN AS CADILA HEALTHCARE LTD.),AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, appeal preferred by the assessee is allowed

ITA 162/AHD/2021[2016-17]Status: DisposedITAT Ahmedabad30 May 2024AY 2016-17

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 162/Ahd/2021 ("नधा"रण वष" / Assessment Years : 2016-17)

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 144BSection 144C(13)Section 153Section 92BSection 92C

69,939/-, on which, net profit before tax has been declared at Rs.24,33,45,21,094/-. The assessee has shown income from house property, capital gain and other sources. During the course of assessment proceeding, it was noticed that the assessee had entered into international transaction as well specified domestic transaction. Further that, it was noticed that transfer pricing

MUJMMEEL ,KOTA vs. ACIT-CENTRAL CIRCLE , KOTA

In the result, appeal of the assessee is allowed

ITA 620/JPR/2024[2020-21]Status: DisposedITAT Jaipur14 Feb 2025AY 2020-21

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Miss. Swatika Jha, AdvFor Respondent: Ms. Alka Gautam, CIT a
Section 115BSection 133ASection 139Section 143(2)Section 143(3)Section 263Section 69Section 69A

69 is speculative and overlooks the documentary evidence provided by the assessee- appellant. The ld. AO’s actions adhered strictly to procedural norms, ensuring that the assessment order was both fair and lawful. 33. That the Ld. PCIT’s assumptions conflict with established precedents and the evidence presented during the assessment process. Established jurisprudence holds that tax authorities must base

M/S. ESSAR SHIPPING LTD,MUMBAI vs. DCIT, CIRCLE 5(1)(1), MUMBAI

In the result, the appeal of the assessee is In the result, the appeal of the assessee is dismissed

ITA 6521/MUM/2024[2021-22]Status: DisposedITAT Mumbai30 May 2025AY 2021-22

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2021-22 M/S Essar Shipping Ltd., Dy. Cit, Circle 5(1)(1), 5Th Floor, Essar House, 11, Keshav Mumbai/Assessment Unit, Vs. Rao Khadye Marg, Mahalaxmi National Faceless Assessment Mumbai-400034. Centre, Room No. 568, Aayakar Bhavan, M.K. Road, Mumbai-400020. Pan No. Aacce 3707 D Appellant Respondent

For Appellant: Mr. Suresh Gaikwad, Sr. DRFor Respondent: Mr. Piyush Chaturvedi
Section 115B

69,83,120/ 3. Aggrieved, the assessee is in appeal before the Tribunal by way the assessee is in appeal before the Tribunal by way the assessee is in appeal before the Tribunal by way of grounds reproduced above. of grounds reproduced above. M/s Essar Shipping Ltd M/s Essar Shipping Ltd 4. Before us, the Ld. counsel for the assessee

ATOS INDIA P.LTD,MUMBAI vs. DCIT RG 14(1)(1), MUMBAI

In the result, the appeal filed by the assessee stands allowed on the additional grounds

ITA 1795/MUM/2017[2012-13]Status: DisposedITAT Mumbai23 Feb 2023AY 2012-13

Bench: Shri G. S. Pannu & Shri Amit Shukla, Jm आयकरअपीलसं./ I.T.A. No. 1795/Mum/2017 (ननधधारणवर्ा / Assessment Year: 2012-13) Dcit-14(1)1), Atos India Pvt. Ltd., Aayakar Bhavan Godrej & Boyce Complex, बनाम/ Mumbai Plant 5, Pirojshanagar, Vs. Lbs Marg, Vikhroli (West), Mumbai-400079 स्थधयीलेखधसं./जीआइआरसं./ Pan No. Aaaco2461J (अपीलधथी/Appellant) (प्रत्यथी / Respondent) : अपीलधथीकीओरसे/ Appellant By : Shri Dhanesh Bafna /Chandni Sha /Riddhi Maru /Kinjal Patel, Ld. Ars प्रत्यथीकीओरसे/Respondent By : Dr. Yogesh Kamat, Ld. Dr सुनवधईकीतधरीख/ 01.06.2022 & : 25.01.2023 Date Of Hearing घोर्णधकीतधरीख / : 23.02.2023 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: 1. The Aforesaid Appeal Has Been Filed By The Assessee Against The Final Assessment Order Passed U/S 143(3) R.W.S. 144C(13) In 2

For Appellant: Shri Dhanesh BafnaFor Respondent: Dr. Yogesh Kamat
Section 10ASection 143(3)Section 144CSection 153Section 40Section 40(3)Section 48Section 4oSection 92C

section 153 of the Act, thus making the final assessment order illegal, bad in law, null and void and liable to be quashed. Additional Ground No. 4: On the facts and in the circumstances of the case and in law, the Appellant prays that the amount of Education Cess and Higher and Secondary Education Cess charged on income tax during

THOMAS COOK (INDIA) LTD.,MUMBAI vs. ADDL/ JT/ DY/CIT/ASSTT/ITO, NATIONAL E-ASSESSMENT CENTRE, DELHI

In the result, appeal filed by the assessee is partly allowed

ITA 1218/MUM/2021[2016-17]Status: DisposedITAT Mumbai24 Nov 2023AY 2016-17

Bench: Shri S. Rifaur Rahman, Hon'Ble & Ms. Kavitha Rajagopal, Hon'Ble

Section 92CSection 92C(3)

Transfer Pricing Officer to benchmark the same and determine the ALP i.e., the difference of dividend of 8.5% and the LIBOR rate as per above discussion. Accordingly, we are inclined to allow the Ground No.1 raised by the assessee for statistical purpose. It is needless to say that the bench marking may be carried out by the Page

SHAPOORJI PALLONJI AND COMPANY PVT LTD,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 8(3), MUMBAI

Appeals are partly allowed

ITA 1149/MUM/2025[2013-14]Status: DisposedITAT Mumbai23 Jan 2026AY 2013-14

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI JAGADISH (Accountant Member)

For Appellant: Shri Rajan Vora, Shri Nikhil TiwariFor Respondent: Shri Ajay Chandra & Shri Pravin
Section 143(3)Section 144C(3)Section 92Section 92B

Section 115JB of the Act. 50. Aggrieved by the Assessment Order, the Assessee preferred appeal before the Learned CIT(A). The Learned CIT(A) vide Order, dated 23/12/2024, provided partial relief in respect of the transfer pricing adjustment. The Learned CIT(A) deleted the Transfer Pricing Assessment Year 2012-2013 & 2013-2014 Addition of INR.10,45,07,474/- made

SHAPOORJI PALLONJI AND COMPANY PRIVATE LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE -3(3)(1), MUMBAI

Appeals are partly allowed

ITA 1150/MUM/2025[2012-13]Status: DisposedITAT Mumbai23 Jan 2026AY 2012-13

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI JAGADISH (Accountant Member)

For Appellant: Shri Rajan Vora, Shri Nikhil TiwariFor Respondent: Shri Ajay Chandra & Shri Pravin
Section 143(3)Section 144C(3)Section 92Section 92B

Section 115JB of the Act. 50. Aggrieved by the Assessment Order, the Assessee preferred appeal before the Learned CIT(A). The Learned CIT(A) vide Order, dated 23/12/2024, provided partial relief in respect of the transfer pricing adjustment. The Learned CIT(A) deleted the Transfer Pricing Assessment Year 2012-2013 & 2013-2014 Addition of INR.10,45,07,474/- made

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

In the result, the appeal of the assessee

ITA 1035/MUM/2016[2011-12]Status: DisposedITAT Mumbai10 Feb 2023AY 2011-12

Bench: Shri Om Prakash Kant () & Shri Kavitha Rajagopal () Assessment Year: 2011-12 Lanxess India Pvt. Ltd., Dy. Cit, Circle-1, Lanxess House, Plot No. Room No. 22, 6Th Floor, B A/162-164, Road No. 27, Vs. Wing Asher It Park, Road, Wagle Estate, Opp. Iti College, 16-Z, Wagle Industrial Midc, Thane (West)-400 604. Estate, Thane (West)-400604. Pan No. Aaccb 3880 A Appellant Respondent Assessment Year: 2011-12 Dy. Cit, Circle-1, Lanxess India Pvt. Ltd., Room No. 22, 6Th Floor, B Wing Lanxess House, Plot No. Asher It Park, Road, 16-Z, Vs. A/162-164, Road No. 27, Wagle Industrial Estate, Thane Wagle Estate, Opp. Iti (West)-400604. College, Midc, Thane (West)- 400 604. Pan No. Aaccb 3880 A Appellant Respondent

For Appellant: Shri Dhanesh Bafna/Chandni

section 92CA(3) of the Act transfer pricing adjustment to manufacturing segment and transfer pricing adjustment to manufacturing segment and transfer pricing adjustment to manufacturing segment and technical support service. Under manufacturing segment, the Ld. technical support service. Under manufacturing segment, the Ld. technical support service. Under manufacturing segment, the Ld. TPO computed adjustment for Nagada plant at Rs.2

DCIT CIR 1, THANE vs. LAXCESS INDIA P.LTD, THANE

In the result, the appeal of the assessee

ITA 1697/MUM/2016[2011-12]Status: DisposedITAT Mumbai10 Feb 2023AY 2011-12

Bench: Shri Om Prakash Kant () & Shri Kavitha Rajagopal () Assessment Year: 2011-12 Lanxess India Pvt. Ltd., Dy. Cit, Circle-1, Lanxess House, Plot No. Room No. 22, 6Th Floor, B A/162-164, Road No. 27, Vs. Wing Asher It Park, Road, Wagle Estate, Opp. Iti College, 16-Z, Wagle Industrial Midc, Thane (West)-400 604. Estate, Thane (West)-400604. Pan No. Aaccb 3880 A Appellant Respondent Assessment Year: 2011-12 Dy. Cit, Circle-1, Lanxess India Pvt. Ltd., Room No. 22, 6Th Floor, B Wing Lanxess House, Plot No. Asher It Park, Road, 16-Z, Vs. A/162-164, Road No. 27, Wagle Industrial Estate, Thane Wagle Estate, Opp. Iti (West)-400604. College, Midc, Thane (West)- 400 604. Pan No. Aaccb 3880 A Appellant Respondent

For Appellant: Shri Dhanesh Bafna/Chandni

section 92CA(3) of the Act transfer pricing adjustment to manufacturing segment and transfer pricing adjustment to manufacturing segment and transfer pricing adjustment to manufacturing segment and technical support service. Under manufacturing segment, the Ld. technical support service. Under manufacturing segment, the Ld. technical support service. Under manufacturing segment, the Ld. TPO computed adjustment for Nagada plant at Rs.2

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

The appeals are allowed in the above terms, but with no orders as to costs

ITA/110/2014HC Delhi11 Dec 2015
Section 260ASection 92C

transfer pricing 'adjustment'. This runs counter to legal position explained in CIT v. EKL Appliances Ltd. (2012) 345 ITR 241 (Del), which required a TPO "to examine the ‘international transaction’ as he actually finds the same.” In other words the very existence of an international transaction cannot be a matter for inference or surmise. 65. As already noticed, the decision

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

The appeals are allowed in the above terms, but with no orders as to costs

ITA/710/2015HC Delhi11 Dec 2015
Section 260ASection 92C

transfer pricing 'adjustment'. This runs counter to legal position explained in CIT v. EKL Appliances Ltd. (2012) 345 ITR 241 (Del), which required a TPO "to examine the ‘international transaction’ as he actually finds the same.” In other words the very existence of an international transaction cannot be a matter for inference or surmise. 65. As already noticed, the decision

COLGATE PALMOLIVE (INDIA) LTD,MUMBAI vs. ASST CIT CIR 15(1)(2), MUMBAI

Accordingly, number 75/M/2018 filed by the assessee for assessment year 2013 – 14 is allowed

ITA 75/MUM/2018[2013-14]Status: DisposedITAT Mumbai11 Apr 2023AY 2013-14

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

For Appellant: Shri Madhur AgrawalFor Respondent: Dr. Yogesh Kamat, CIT DR
Section 115JSection 143(3)Section 144CSection 14ASection 80ISection 92C

transfer pricing issues of ₹23,48,70,000/-. v. The learned Assessing Officer further made disallowance under Section 14A read with Rule 8D of the Rule of ₹25,21,108/-. The assessee claimed deduction under Section 80IC of the Act amounting to ₹83,40,16,776/- which was restricted to ₹83,06,69

DCIT 15(1)(2), MUMBAI vs. COLGATE PALMOLIVE (INDIA) LTD., MUMBAI

Accordingly, number 75/M/2018 filed by the assessee for assessment year 2013 – 14 is allowed

ITA 2799/MUM/2016[2011-12]Status: DisposedITAT Mumbai11 Apr 2023AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

For Appellant: Shri Madhur AgrawalFor Respondent: Dr. Yogesh Kamat, CIT DR
Section 115JSection 143(3)Section 144CSection 14ASection 80ISection 92C

transfer pricing issues of ₹23,48,70,000/-. v. The learned Assessing Officer further made disallowance under Section 14A read with Rule 8D of the Rule of ₹25,21,108/-. The assessee claimed deduction under Section 80IC of the Act amounting to ₹83,40,16,776/- which was restricted to ₹83,06,69

COLGATE PALMOLIVE (INDIA) LTD,MUMBAI vs. ASST CIT CIR 15(1)(2), MUMBAI

Accordingly, number 75/M/2018 filed by the assessee for assessment year 2013 – 14 is allowed

ITA 3488/MUM/2016[2011-12]Status: DisposedITAT Mumbai11 Apr 2023AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

For Appellant: Shri Madhur AgrawalFor Respondent: Dr. Yogesh Kamat, CIT DR
Section 115JSection 143(3)Section 144CSection 14ASection 80ISection 92C

transfer pricing issues of ₹23,48,70,000/-. v. The learned Assessing Officer further made disallowance under Section 14A read with Rule 8D of the Rule of ₹25,21,108/-. The assessee claimed deduction under Section 80IC of the Act amounting to ₹83,40,16,776/- which was restricted to ₹83,06,69

COLGATE -PALMOLIVE (INDIA) LTD,MUMBAI vs. ASST CIT CIR 15(1)(2), MUMBAI

Accordingly, number 75/M/2018 filed by the assessee for assessment year 2013 – 14 is allowed

ITA 1977/MUM/2017[2012-13]Status: DisposedITAT Mumbai11 Apr 2023AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

For Appellant: Shri Madhur AgrawalFor Respondent: Dr. Yogesh Kamat, CIT DR
Section 115JSection 143(3)Section 144CSection 14ASection 80ISection 92C

transfer pricing issues of ₹23,48,70,000/-. v. The learned Assessing Officer further made disallowance under Section 14A read with Rule 8D of the Rule of ₹25,21,108/-. The assessee claimed deduction under Section 80IC of the Act amounting to ₹83,40,16,776/- which was restricted to ₹83,06,69

M/S NIKHIL ESTATE P LTD,INDORE vs. THE ACIT CENTRAL CIRCLE (3) INDORE, INDORE

In the result, appeal of assessee is allowed

ITA 28/IND/2023[2019-20]Status: DisposedITAT Indore09 Jun 2023AY 2019-20

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S. Nikhil Estate Pvt. Ltd. Acit (Central)-3 M-102, Mezzanine, Floor, Indore Dhan Trident, P. No.B-3 Pu- Vs. 4, Sch. No.54, Vijay Nagar Square, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aabcn 8056 D Assessee By Shri S.S. Solanki, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 01.05.2023 Date Of Pronouncement 09.06.2023

Section 115BSection 133ASection 69Section 69B

69, 69B or 69D is like an open ended hypothesis which is not supported by any specific finding that the matter shall fall under which of the specific sections and how the conditions stated therein are satisfied before the said provisions are invoked. It is like laying a general rule, which to our mind is beyond the mandate