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6,956 results for “transfer pricing”+ Section 92clear

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Key Topics

Section 143(3)91Addition to Income53Section 153A39Disallowance31Section 14A25Deduction20Transfer Pricing20Section 25016Section 14712Section 92C

LAXMI HYDROCOLLOIDS,AHMEDABAD vs. ITO, WARD-3(2)(8), AHMEDABAD

In the result, the appeal filed by the assessee in ITA No

ITA 416/AHD/2019[2014-15]Status: DisposedITAT Ahmedabad23 Mar 2022AY 2014-15

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedआयकर अपील सं./Ita No. 416/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2014-2015 Laxmi Hydrocolloids, I.T.O., Plot No.104, Vs. Ward-3(2)(8), Devraj Industrial Estate, Ahmedabad. Piplej Pirana Road, Ahmedabad-380022. Pan: Aaefl2440D

For Appellant: Shri Jaymin Shah, A.RFor Respondent: Shri Purushottam Kumar, Sr.D.R
Section 92Section 92B

section 92-BI and reference made to the order of Transfer Pricing Officer-TCP under section 92-CA could be invalid

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

Showing 1–20 of 6,956 · Page 1 of 348

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12
Section 10A12
Section 50C11
ITA 1549/KOL/2009[2004-05]Status: Disposed
ITAT Kolkata
15 Jul 2016
AY 2004-05

Bench: The Special Bench:

transfer pricing cannot be pressed into service in this case. Learned counsel submits that an arm’s length price adjustment is permissible and will be in accordance with the law only as long as it does not result in base erosion. Section 92

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

In the result, assessee’s appeal is partly allowed

ITA 2590/MUM/2017[2012-13]Status: DisposedITAT Mumbai23 Jul 2018AY 2012-13

Bench: Shri Saktijit Dey & Shri Rajesh Kumar

For Appellant: Shri Dhanesh Bafnaa/wFor Respondent: Shri Jayant Kumar
Section 143(3)Section 144C(13)

92 of the Act provides for computation of income arising from international transaction at arm's length price. Section 92C of the Act provides for determination of arm's length price of an international transaction by applying the most appropriate method having regard to the nature of transaction for class of transaction or functions performed, etc. The most appropriate method

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)

92,530. In the course of assessment proceedings, the Assessing Officer noticing that assessee has entered into international transactions with its A.E. made a reference to the Transfer Pricing Officer (Transfer Pricing Officer) for determining the arm's length price (arm's length price). In the course of proceedings before him, the Transfer Pricing Officer after verifying the records noticed

COMMISSIONER OF INCOME TAX vs. AMADEUS INDIA PVT LTD

Appeal is dismissed

ITA/938/2011HC Delhi28 Nov 2011
For Appellant: Ms Suruchi AggarwalFor Respondent: Mr M.S. Syali, Sr. Advocate with Mr Mayank Nagi &
Section 144CSection 260ASection 92BSection 92CSection 92E

Section 92CA(1) of the said Act, after taking the statutory approval from the Commissioner of Income Tax, Delhi-I, New Delhi on 23.10.2009. The Transfer Pricing Officer, by virtue of his order dated 23.10.2009, adjusted an amount of ` 32,92

PCIT-1, NEW DELHI vs. BEAM GLOBAL SPIRITS & WINE (INDIA)PVT.LTD.

ITA/155/2022HC Delhi07 Mar 2025

Bench: HON'BLE MR. JUSTICE HARISH VAIDYANATHAN SHANKAR,HON'BLE MR. JUSTICE YASHWANT VARMA

Section 92BSection 92F

transfer pricing in the form of sections 92B to 92F. 59. Nevertheless, there is no specific mention of AMP expenses as one of the items of expenditure which can be deemed to be an international transaction. For this purpose, section 92B(1) read with section 92

PCIT-1, NEW DELHI vs. BEAM GLOBAL SPIRITS & WINE (INDIA) PVT. LTD.

ITA/156/2022HC Delhi07 Mar 2025

Bench: HON'BLE MR. JUSTICE HARISH VAIDYANATHAN SHANKAR,HON'BLE MR. JUSTICE YASHWANT VARMA

Section 92BSection 92F

transfer pricing in the form of sections 92B to 92F. 59. Nevertheless, there is no specific mention of AMP expenses as one of the items of expenditure which can be deemed to be an international transaction. For this purpose, section 92B(1) read with section 92

VAN OORD INDIA P.LTD,MUMBAI vs. DCIT RG 5(3), MUMBAI

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

ITA 720/MUM/2015[2010-11]Status: DisposedITAT Mumbai11 Nov 2019AY 2010-11

Bench: Shri. A. D. Jain & Shri Rajesh Kumar

For Appellant: S/Shri Nishant Thakkar, RishiFor Respondent: Shri Rajeev Harit, D.R
Section 115VSection 143(3)Section 144C(13)Section 28Section 43CSection 92Section 92(1)Section 92CSection 92C(4)Section 92E

pricing provisions begin from section 92 and end with 92F. They are contained in chapter X in the special provisions relating to avoidance of tax. As such, it is not correct to interpret that the scheme of Tonnage Tax will override the provisions of section 92 to 90 2F The fact that they are special provisions (Transfer

ACCENTURE SERVICES P.LTD,MUMBAI vs. DCIT CIR 3(1), MUMBAI

In the result, appeal is partly allowed

ITA 1671/MUM/2014[2009-10]Status: DisposedITAT Mumbai28 Jun 2019AY 2009-10

Bench: Shri Saktijit Deyand Shri N.K. Pradhan

For Appellant: Shri P.J. Pardiwalaa/w Shri Hiten ChandeFor Respondent: Shri Anand Mohan
Section 143(3)Section 144C(13)

Transfer Pricing Officer, we do not intend to deal with the acceptability or otherwise of the rest of the comparables disputed before us under ITES segment and leave the issue relating to comparability of these comparables open for adjudication if they arise in any other assessment year in future. 84. Ground no.7, of this appeal is identical to ground no.6

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

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

ITA 6081/MUM/2018[2014-15]Status: DisposedITAT Mumbai07 Jun 2019AY 2014-15

Bench: Shri G Manjunatha () & Shri Ravish Sood () Firmenich Aromatics (India) Vs Acit-9(3)(1), Mumbai Pvt Ltd, 9Th Floor, Arena Space, Cts 20, New Shyam Nagar Road, Behind Majas Bus Depot, Jogeshwari (E), Mumbai. Pan : Aaacf1621M Appellant Respondednt

Section 143(3)Section 144C(5)

92 of the Act provides for computation of income arising from international transaction at arm's length price. Section 92C of the Act provides for determination of arm's length price of an international transaction by applying the most appropriate method having regard to the nature of transaction for class of transaction or functions performed, etc. The most appropriate method

SKF TECHNOLOGIES (INDIA) PRIVATE LIMITED,BANGALORE vs. ACIT, BANGALORE

ITA 1481/BANG/2010[2006-07]Status: DisposedITAT Bangalore31 Mar 2016AY 2006-07

Bench: Shri. Abraham P. George

For Appellant: Shri. K. R. Vasudevan, AdvocateFor Respondent: Shri. G. R. Reddy, CIT – DR -I
Section 144C(5)

section 92(3) a logical inference from the fact that CWS and CWHK have only asked for reimbursement of cost. This being a transaction between related parties, whether that cost itself is inflated or not only is a matter to be tested under a comprehensive transfer pricing

DCIT, NEW DELHI vs. M/S. BBC WORLD INDIA (P) LTD., NEW DELHI

In the result appeal of the assessee and the learned assessing officer are allowed for statistical purposes

ITA 5556/DEL/2014[2007-08]Status: DisposedITAT Delhi18 Oct 2019AY 2007-08

Bench: Shri Kuldip Singh & Shri Prashant Maharishi

Section 250Section 92C

section 92 CA of the act Transfer Pricing officer for the purposes of the section of 92 CA of the act is ‘Explanation

DCIT (LTU) 1, MUMBAI vs. IPCA LABORATORIES LTD, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 2815/MUM/2015[2010-11]Status: DisposedITAT Mumbai29 Aug 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

Transfer Pricing Officer rejected the contention of the assessee and computed the interest on the advance given to subsidiaries in Mauritius, USA and Brazil. He adopted that this Associated Enterprises’ will be categorized in the BB category for which rate of interest is 14.39% and accordingly, adjustment on account of non-charging of interest on advances to Associated Enterprises

IPCA LABORATORIES LTD,MUMBAI vs. ASST CIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3597/MUM/2016[2009-10]Status: DisposedITAT Mumbai29 Aug 2022AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

Transfer Pricing Officer rejected the contention of the assessee and computed the interest on the advance given to subsidiaries in Mauritius, USA and Brazil. He adopted that this Associated Enterprises’ will be categorized in the BB category for which rate of interest is 14.39% and accordingly, adjustment on account of non-charging of interest on advances to Associated Enterprises

IPCA LABORATORIES LTD,MUMBAI vs. DCIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 8084/MUM/2010[2006-07]Status: DisposedITAT Mumbai29 Aug 2022AY 2006-07

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

Transfer Pricing Officer rejected the contention of the assessee and computed the interest on the advance given to subsidiaries in Mauritius, USA and Brazil. He adopted that this Associated Enterprises’ will be categorized in the BB category for which rate of interest is 14.39% and accordingly, adjustment on account of non-charging of interest on advances to Associated Enterprises

ASST CIT (LTU) 1, MUMBAI vs. IPCA LABORATORIES LTD, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3691/MUM/2016[2009-10]Status: DisposedITAT Mumbai29 Aug 2022AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

Transfer Pricing Officer rejected the contention of the assessee and computed the interest on the advance given to subsidiaries in Mauritius, USA and Brazil. He adopted that this Associated Enterprises’ will be categorized in the BB category for which rate of interest is 14.39% and accordingly, adjustment on account of non-charging of interest on advances to Associated Enterprises

DCIT CENT. CIR. 5(2), MUMBAI vs. IPCA LABORATORIES LTD., MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 5227/MUM/2016[2010-11]Status: DisposedITAT Mumbai29 Aug 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

Transfer Pricing Officer rejected the contention of the assessee and computed the interest on the advance given to subsidiaries in Mauritius, USA and Brazil. He adopted that this Associated Enterprises’ will be categorized in the BB category for which rate of interest is 14.39% and accordingly, adjustment on account of non-charging of interest on advances to Associated Enterprises

IPCA LABORATORIES LTD,MUMBAI vs. DCIT LTU, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3811/MUM/2016[2010-11]Status: DisposedITAT Mumbai29 Aug 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

Transfer Pricing Officer rejected the contention of the assessee and computed the interest on the advance given to subsidiaries in Mauritius, USA and Brazil. He adopted that this Associated Enterprises’ will be categorized in the BB category for which rate of interest is 14.39% and accordingly, adjustment on account of non-charging of interest on advances to Associated Enterprises

IPCA LABORATORIES LTD,MUMBAI vs. ACIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 8120/MUM/2010[2005-06]Status: DisposedITAT Mumbai29 Aug 2022AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

Transfer Pricing Officer rejected the contention of the assessee and computed the interest on the advance given to subsidiaries in Mauritius, USA and Brazil. He adopted that this Associated Enterprises’ will be categorized in the BB category for which rate of interest is 14.39% and accordingly, adjustment on account of non-charging of interest on advances to Associated Enterprises

IPCA LABORATORIES LTD,MUMBAI vs. ASST CIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 2493/MUM/2015[2008-09]Status: DisposedITAT Mumbai29 Aug 2022AY 2008-09

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

Transfer Pricing Officer rejected the contention of the assessee and computed the interest on the advance given to subsidiaries in Mauritius, USA and Brazil. He adopted that this Associated Enterprises’ will be categorized in the BB category for which rate of interest is 14.39% and accordingly, adjustment on account of non-charging of interest on advances to Associated Enterprises