Reliance Industries Limited, Mumbai vs Assistant Commissioner Of Income Tax- ... on 10 November, 2020
Reliance Industries Limited, Mumbai vs Assistant Commissioner Of Income Tax- ... on 10 November, 2020
THE
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1 - 10 of 389 (1.02 seconds)Dimension Data Asia Pacific Pte. Ltd, ... vs Dcit (It) 2(1)(2), Mumbai on 5 May, 2017
learned Assessing Officer and the Honourable DRP erred in allowing
an arbitrary deduction of only 10% as expenses and taxing 90% of
the management ... services at cost plus mark up basis and as per terms
of the agreement, it is remunerated at cost + mark-up of 10% for
providing
Vvf (India) Limited,Mumbai vs Income Tax Department National ... on 14 February, 2025
considering Indonesian AE as the tested
party. Assessee used net cost plus marked up (herein after refer
to as NCP) as profit level indicator (herein ... comparables were arbitrary.
The Ld.TPO thus applied profit level indicator of operating profit
over operating cost at entity level to bench mark the transaction
L'Oreal India Private Limited , Mumbai vs Assistant Commissioner Of Income Tax ... on 3 May, 2023
erred in adhoc and arbitrary cherry picking of
comparable companies to apply BLT without following any systematic search process;
Mark-up on AMP expenses
Temasek Holdings Advisors India P.Ltd, ... vs Assessee on 25 February, 2016
providing such personalized
investment services and non-discretionary portfolio management
services, a mark-up of 3% over and above is required to be added ... Thereafter, the TPO has tried
to justify such an adding of a mark-up by referring to the
definitions of Portfolio management services from
Lintas India P.Ltd, Mumbai vs Dcit Cir 3(2)(1), Mumbai on 12 June, 2019
Remarked that the Assessee failed to provide the rationale for
charging a mark-up of 5% on the costs
Stated that the Assessee failed ... charge, as not backed by
any tangible benefit, is arbitrary in nature;
Payment made by assessee to its AE is in accordance with the
agreement
Internatinal Air Transport ... vs Dcit (It) 2(2)(1), Mumbai on 24 August, 2021
Indian branch office) in India, on an arbitrary and ad-hoc basis;
and
ii. Erred in estimating 90% of the gross receipts attributed ... being the profits attributable to such FE in India, on an arbitrary and ad-hoc basis."
As is discernible from the records, we find
Loreal India P.Ltd, Mumbai vs Dcit, Circle 7(1)(2), Mumbai on 23 August, 2019
sales promotion
expense (le 83.5:16.5), in case of comparable companies:
Mark-up on AMP expenses
19. without prejudice to the above, erred in disregarding ... mark-up on
the same;
20. without prejudice to the above, erred in holding that the Appellant should
have earned a mark
Lintas India Private Limited, Mumbai vs Deputy Commissioner Of Income-Tax ... on 7 August, 2019
Remarked that the Assessee failed to provide the rationale for
charging a mark-up of 5% on the costs
Stated that the Assessee failed ... charge, as not backed by any
tangible benefit, is arbitrary in nature;
Payment made by assessee to its AE is in accordance with the agreement
Dcit(It) 1(2)(1), Mumbai vs Barclays Bank Plc, Mumbai on 13 April, 2018
been
selective in his approach and made the order
arbitrary. Had the aggregate of sales made to
the AE and that to the third parties ... goes
against it. Ultimately an order to stand has to
have a mark of fairness, reasonableness and
judiciousness. Taking all the above facts and
circumstances