Company
March March 2006 March
2006 2006
Sales PBIT TC OP/TC OP/Sales
(NOI,NNRT) (%) (%)
Britannia 1821.17 167.76 1653.41 10.15 9.21
Industries Ltd.
Colgate ... Operating Margin OP/OS 7,618 51,474 59,092
Operating Margin OP/OC 6.14% 2.95% 3.16%
(%) on sales
Operating Margin OP
Total cost (other than interest cost) 244.75
Profit 7.17%
OP/TC 2.92%
OP/Sales 2.85%
3.5 For the sake of completeness the arithmetical mean ... OP/Sales at 23.486%. The details are as under:
(In %) OP/TC OP/Sales
1. Engineers India Ltd. 28.9 22.42
2 ILFS Transportation
Indicator (PLI) of
OP / TC. The assessee chose nine comparable cases with the average
of OP / TC at 4.43% and OP / Sales ... also did not accept the assessee's adoption of OP / TC or
OP/Sales as correct PLI. In his opinion the correct
Limited
Saraswat Co-op Bank, Citizens Credit Co-op Bank, Mumbai District Central Co-
op Bank, and Maharashtra State Co-op Bank Limited aggregating ... decision of Hon'ble Apex Court in
Totgars Co-op Sale Society
Even Hon'ble Karnataka High Court PCIT v. Tatagars Co-op. Sale Society
[2017] 78 taxmann.com 169 (Karnataka) also held that ... assessee
relied on the following decisions;
PCIT v. Tatagars Co-op. Sale Society [2017] 78 taxmann.com 169
(Karnataka),
Kaliandas Udyog Bhavan Premises Co-operative
reference to the computation of the Operating
Profit to Sales ("OP/Sales") of comparable companies, erred in:
a) Disregarding the computation of OP ... proceedings
before the Ld. Panel;
b) confirming the computation of OP/Sales provided by the TPO during the
proceedings before the Ld. Panel vide
computed the arithmetic
mean of three comparables by using OP/sales as PLI and arrived the
ALP at 9.60% in comparison to the assessee ... operating margin
(OP/sales) at 6.18%. Accordingly, the TPO made an addition of `
58,57,133/- to the price of international transactions being purchase
Mumbai vs The Bombay Sales Tax Staff Co Op Credit ... on 31 May, 2018
P a g e |1
ITA No.7064/Mum/2013 ... Bombay Sales Tax Staff Co-op.
IN THE INCOME TAX APPELLATE TRIBUNAL "B" BENCH, MUMBAI
BEFORE SHRI R.C.SHARMA, AM AND SHRI
Supreme Court decision in the case of Totgar Co-op. Sales Society Ltd. and
latest Hon'ble Karnataka High Court decision in the case ... PCIT, Hubli v/s.
Totgar Co-op. Sales Society 392 ITR 74 (ITA No-100069/2016) as the
Appellant Society has not made investment
manufacturing of chemicals and identified 10 comparables
comparable having
arithmetic mean (OP/Sales) of 5.73% using multiple year data.
data The
Ld. TPO directed ... comparables at 9.78%, as under:
S. No. Company Name Segment Name OP/Sales OP/TC
1. Alkyl Amines Chemicals Ltd. 12.98% 14.92%
2. Balaji Amines
