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Bekaert Industries P. Ltd, Pune vs Acit, Pune on 14 May, 2018 cites

Nivea India P.Ltd, Mumbai vs Dcit 10(3)(1), Mumbai on 21 March, 2018

stage and because of certain reasons, evidence could not be filed before the TPO but was filed by way of additional evidence before the DRP, which merits to be accepted. He then, relied on the ratio laid down by the Mumbai Bench of Tribunal in M/s. Nivea India Pvt. Ltd. Vs. DCIT in ITA No.121/M/2013, relating to assessment year 2007-08, order dated 21.08.2017 for the proposition that additional evidence filed before the Assessing Officer needs to be accepted. The learned Authorized Representative for the assessee also pointed out that no adjustment on this count was made in any of earlier years, wherein similar benchmarking was accepted. In respect of additional ground of appeal No.6 raised by the assessee, the learned Authorized Representative for the assessee stressed that in case the matter was remitted back, then additional ground of appeal raised therein, was on without prejudice basis.
Income Tax Appellate Tribunal - Mumbai Cites 23 - Cited by 1 - Full Document

Commissioner Of Income-Tax vs Jodhan Real Estate Development Co. P. ... on 4 October, 2002

In this regard, reliance was placed on the ratio laid down by the Hon'ble Bombay High Court in CIT Vs. L'Oreal India P. Ltd. in Income Tax Appeal No.1046 of 2012, judgment dated 07.11.2014. He further pointed out that margins of assessee and of comparables by applying RPM method may be verified by the Assessing Officer / TPO.
Rajasthan High Court - Jaipur Cites 14 - Cited by 32 - N N Mathur - Full Document

Kamdhenu Real Estates Pvt. Ltd.,, Pune vs Assistant Commissioner Of ... on 30 November, 2016

In this regard, it submits that even the Hon'ble Bombay High Court has accepted the said proposition of assessee in CIT Vs. L'Oreal India Pvt. Ltd. (supra). In the facts of the case before the Hon'ble Bombay High Court, RPM method was accepted in prior and subsequent assessment years and since the method was one of the standard method and even where OECD guidelines were applied in case of distribution or marketing activities, where the goods are purchased from associated enterprises and sales were effected to unrelated parties without any further processing, then such a method was to be adopted. The Hon'ble High Court observed that the findings of fact were based on materials which was produced before the authorities below and since RPM method was accepted by the TPO in preceding as well as in succeeding assessment years in respect of distribution segment activity of the assessee, then the same should not be disturbed.
Income Tax Appellate Tribunal - Pune Cites 20 - Cited by 2 - Full Document
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