ROHA DYECHEM PVT.LTD.,MUMBAI vs. ACIT-CENTRAL CIRCLE 43, MUMBAI

In the result, all the appeals of the assessee and revenue except ITA No

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

Transfer pricing officer („TPO‟), which not in accordance with the provisions of Section 92CA(1) of the Act. 2. The Appellant prays that the proceedings initiated by the learned TPO under Section 92CA of the Act on the basis of the said reference by the AO be held as void ab initio and that the order passed by the learned

ACIT CC-43, MUMBAI vs. ROHA DYECHEM P. LTD, MUMBAI

In the result, all the appeals of the assessee and revenue except ITA No

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

Transfer pricing officer („TPO‟), which not in accordance with the provisions of Section 92CA(1) of the Act. 2. The Appellant prays that the proceedings initiated by the learned TPO under Section 92CA of the Act on the basis of the said reference by the AO be held as void ab initio and that the order passed by the learned

ROHA DYECHEM PVT.LTD.,MUMBAI vs. ACIT-CENTRAL CIRCLE 43, MUMBAI

In the result, all the appeals of the assessee and revenue except ITA No

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

Transfer pricing officer („TPO‟), which not in accordance with the provisions of Section 92CA(1) of the Act. 2. The Appellant prays that the proceedings initiated by the learned TPO under Section 92CA of the Act on the basis of the said reference by the AO be held as void ab initio and that the order passed by the learned

ACIT CC-43, MUMBAI vs. ROHA DYECHEM P. LTD, MUMBAI

In the result, all the appeals of the assessee and revenue except ITA No

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

Transfer pricing officer („TPO‟), which not in accordance with the provisions of Section 92CA(1) of the Act. 2. The Appellant prays that the proceedings initiated by the learned TPO under Section 92CA of the Act on the basis of the said reference by the AO be held as void ab initio and that the order passed by the learned

ROHA DYECHEM P. LTD,MUMBAI vs. ACIT CEN CIR 43, MUMBAI

In the result, all the appeals of the assessee and revenue except ITA No

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

Transfer pricing officer („TPO‟), which not in accordance with the provisions of Section 92CA(1) of the Act. 2. The Appellant prays that the proceedings initiated by the learned TPO under Section 92CA of the Act on the basis of the said reference by the AO be held as void ab initio and that the order passed by the learned

ROHA DYECHEM P. LTD,MUMBAI vs. ACIT CEN CIR 43, MUMBAI

In the result, all the appeals of the assessee and revenue except ITA No

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

Transfer pricing officer („TPO‟), which not in accordance with the provisions of Section 92CA(1) of the Act. 2. The Appellant prays that the proceedings initiated by the learned TPO under Section 92CA of the Act on the basis of the said reference by the AO be held as void ab initio and that the order passed by the learned

ACIT CEN CI-43 vs. ROHA DYECHEM P. LTD, MUMBAI

In the result, all the appeals of the assessee and revenue except ITA No

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

Transfer pricing officer („TPO‟), which not in accordance with the provisions of Section 92CA(1) of the Act. 2. The Appellant prays that the proceedings initiated by the learned TPO under Section 92CA of the Act on the basis of the said reference by the AO be held as void ab initio and that the order passed by the learned

ACIT CC-43, MUMBAI vs. ROHA DYECHEM P. LTD, MUMBAI

In the result, all the appeals of the assessee and revenue except ITA No

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

Transfer pricing officer („TPO‟), which not in accordance with the provisions of Section 92CA(1) of the Act. 2. The Appellant prays that the proceedings initiated by the learned TPO under Section 92CA of the Act on the basis of the said reference by the AO be held as void ab initio and that the order passed by the learned

DCIT(CC)-8(3), MUMBAI vs. JSW ENERGY LIMITED, MUMBAI

In the result the appeals filed by the revenue for assessment years under consideration stands partly allowed and cross appeals filed by the assesse stands dismissed

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

transfer of goods and services is in consonance with the price available in the open market then the profits of the eligible business shown as per this price is eligible for deduction and in that case the second option may not be necessary. 13.9. It is noted that Co-ordinate Bench of this Tribunal in the case of Tata Chemicals

M/S. TATA CHEMICALS LTD,MUMBAI vs. DCIT2(3) (1) - , MUMBAI

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

transfer pricing provision for determining the arm‟s length price. 16 M/s. Tata Chemicals Ltd. 14. The entire case of the department is that, since it is SDT in term of Section 80I

KBS CREATION LTD ,MUMBAI vs. DY COMM. OF INCOME TAX -CIRCLE 24(1), MUMBAI

In the result, the concise ground of appeal of the assessee is allowed

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

transfer pricing provisions is bad in law. The assessee is also stated that AO referred the matter to TPO in respect of SDT without demonstrating that business affairs of the assessee with the closely connected entity has been so arranged having risen to more than the ordinary profit of the assessee. The assessee by refereeing sub-section (10) of section

SYNGENTA INDIA LTD,PUNE vs. ADDL CIT RG 1(3), MUMBAI

In the result, appeal of the revenue stands dismissed

Bench: Shri R. C. Sharma & Shri Amit Shuklait(Tp)A No.: 1373/Mum/2014 (Assessment Year 2009-10) ससिंगएनता इिंडिमा प्राइवेट सरसभटेि Vs Dy. Cit- 1(3), Room No.564, Syngenta India Ltd., Aayakar Bhavan, S No. 110/11/3, Amar Paradigm M K Road, Mumbai – 400 020 Baner Road, Pune -411 045 स्थमी रेखा सिं. Pan: Aaecs 9424 P अऩीराथी (Appellant) प्रत्मथी (Respondent)

section 80IB, the profit and loss for 4 units for the year as well as profits eligible for deduction as per the assessee and as per the revenue is as under: Particular Multipurpose Thiamethoxam Topik Profenofos Total Unit Unit Unit Profit/loss for the year

DCIT 1(3), MUMBAI vs. SYNGENTA INDIA LTD, PUNE

In the result, appeal of the revenue stands dismissed

Bench: Shri R. C. Sharma & Shri Amit Shuklait(Tp)A No.: 1373/Mum/2014 (Assessment Year 2009-10) ससिंगएनता इिंडिमा प्राइवेट सरसभटेि Vs Dy. Cit- 1(3), Room No.564, Syngenta India Ltd., Aayakar Bhavan, S No. 110/11/3, Amar Paradigm M K Road, Mumbai – 400 020 Baner Road, Pune -411 045 स्थमी रेखा सिं. Pan: Aaecs 9424 P अऩीराथी (Appellant) प्रत्मथी (Respondent)

section 80IB, the profit and loss for 4 units for the year as well as profits eligible for deduction as per the assessee and as per the revenue is as under: Particular Multipurpose Thiamethoxam Topik Profenofos Total Unit Unit Unit Profit/loss for the year

SYNGENTA INDIA LTD,PUNE vs. ASST CIT RG 1(3)(1), MUMBAI

In the result, appeal of the revenue stands dismissed

Bench: Shri R. C. Sharma & Shri Amit Shuklait(Tp)A No.: 1373/Mum/2014 (Assessment Year 2009-10) ससिंगएनता इिंडिमा प्राइवेट सरसभटेि Vs Dy. Cit- 1(3), Room No.564, Syngenta India Ltd., Aayakar Bhavan, S No. 110/11/3, Amar Paradigm M K Road, Mumbai – 400 020 Baner Road, Pune -411 045 स्थमी रेखा सिं. Pan: Aaecs 9424 P अऩीराथी (Appellant) प्रत्मथी (Respondent)

section 80IB, the profit and loss for 4 units for the year as well as profits eligible for deduction as per the assessee and as per the revenue is as under: Particular Multipurpose Thiamethoxam Topik Profenofos Total Unit Unit Unit Profit/loss for the year