Disclosure of Updates to Ongoing Tax Litigations or Disputes
The updates on tax litigations or disputes in terms of sub-para 8 of para B of Part A of Schedule III read with corresponding provisions of Annexure 18 of the Master Circular are given below: |
Any Other Information for Disclosure of Updates to Ongoing Tax Litigations or Disputes | |
Sr. No. | Name of the opposing party | Date of initiation of the litigation / dispute | Status of the litigation / dispute as per last disclosure | Current status of the litigation / dispute |
1 | Income tax Department/Assessing Officer | 27-01-2022 | For assessment year 2006-07 The Assessing officer have erred in proposing an adjustment of INR 4,89,58,700 to the arm’s length price of the ‘international transactions’ and The Company has filed an appeal before Income tax appelate tribunal (ITAT) | The Assessing officer have erred in proposing an adjustment of INR 4,89,58,700 to the arm’s length price of the ‘international transactions’ and The Company has filed an appeal before ITAT and pending with ITAT. |
2 | Income tax Department/Assessing Officer | 18-03-2015 | For assessment year 2010-11, Transfer pricing adjustment amounting to INR 12,98,92,206 pertaining to payment of royalty by arbitrarily determining the arm’s length price (“ALP”) of the international transaction as against computed by MSL in accordance with the provisions of the Act read with the Income-tax Rules, 1962 (“Rules”) using TNMM Method and / or CUP and the Company has filed an appeal before ITAT | For assessment year 2006-07 • Transfer pricing adjustment amounting to INR 12,98,92,206 pertaining to payment of royalty by arbitrarily determining the arm’s length price (“ALP”) of the international transaction as against computed by MSL in accordance with the provisions of the Act read with the Income-tax Rules, 1962 (“Rules”) using TNMM Method and / or CUP and The Company has filed an appeal before ITAT and the same is pending |
3 | Income tax Department/Assessing Officer | 28-07-2022 | For Assessment year 2011-12, Transfer pricing adjustment amounting to INR 10,16,83,851 pertaining to payment of royalty by arbitrarily determining the arm’s length price (“ALP”) of the international transaction as against computed by MSL in accordance with the provisions of the Act read with the Income-tax Rules, 1962 (“Rules”) using TNMM Method and / or CUP and the Company has filed an appeal before ITAT | For Assessment year 2011-12, Transfer pricing adjustment amounting to INR 10,16,83,851 pertaining to payment of royalty by arbitrarily determining the arm’s length price (“ALP”) of the international transaction as against computed by MSL in accordance with the provisions of the Act read with the Income-tax Rules, 1962 (“Rules”) using TNMM Method and / or CUP and the Company has filed an appeal before ITAT and the same is pending |
4 | Income tax Department/Assessing Officer | 20-12-2016 | For Assessment year 2012-13,Transfer pricing adjustment amounting to INR 43,27,43,656 pertaining to payment of royalty by arbitrarily determining the arm’s length price (“ALP”) of the international transaction as against computed by MSL in accordance with the provisions of the Act read with the Income-tax Rules, 1962 (“Rules”) using TNMM Method and / or CUP and the Company has filed an appeal before ITAT | For Assessment year 2012-13,Transfer pricing adjustment amounting to INR 43,27,43,656 pertaining to payment of royalty by arbitrarily determining the arm’s length price (“ALP”) of the international transaction as against computed by MSL in accordance with the provisions of the Act read with the Income-tax Rules, 1962 (“Rules”) using TNMM Method and / or CUP and the Company has filed an appeal before ITAT and the same is pending |
5 | Income tax Department/Assessing Officer | 01-09-2017 | For Assessment year 2013-14, The TPO benchmarked the manufacturing segment and after adopting new set of comparable under TNMM method, made an adjustment of INR 2,98,05,992 along with adjustment of INR 2,24,267 in respect of inter-unit transfers of semi-finished goods and the Company has filed an appeal before ITAT | For Assessment year 2013-14, The TPO benchmarked the manufacturing segment and after adopting new set of comparable under TNMM method, made an adjustment of INR 2,98,05,992 along with adjustment of INR 2,24,267 in respect of inter-unit transfers of semi-finished goods and the Company has filed an appeal before ITAT and the same is pending |
6 | Income tax Department/Assessing Officer | 05-05-2021 | For Assessment year 2016-17 Transfer pricing adjustment amounting to INR 18,09,75,549 pertaining to payment of royalty by arbitrarily determining the arm’s length price (“ALP”) of the international transaction as against computed by MSL in accordance with the provisions of the Act read with the Income-tax Rules, 1962 (“Rules”) using TNMM Method and / or CUP. Further Transfer pricing adjustment amounting to INR 1,70,78,336 pertaining to manufacturing segment on account of cherry picking of certain comparable companies and the Company has filed an appeal before ITAT | For Assessment year 2016-17 Transfer pricing adjustment amounting to INR 18,09,75,549 pertaining to payment of royalty by arbitrarily determining the arm’s length price (“ALP”) of the international transaction as against computed by MSL in accordance with the provisions of the Act read with the Income-tax Rules, 1962 (“Rules”) using TNMM Method and / or CUP. Further Transfer pricing adjustment amounting to INR 1,70,78,336 pertaining to manufacturing segment on account of cherry picking of certain comparable companies and the Company has filed an appeal before ITAT and the same is pending. |
7 | Income tax Department/Assessing Officer | 07-04-2022 | For Assessment year 2017-18, Transfer pricing adjustment amounting to INR 17,54,70,201 pertaining to payment of royalty by arbitrarily determining the arm’s length price (“ALP”) of the international transaction as against computed by MSL in accordance with the provisions of the Act read with the Income-tax Rules, 1962 (“Rules”) using TNMM Method and / or CUP. Further Transfer pricing adjustment amounting to INR 2,35,38,892 pertaining to manufacturing segment on account of cherry picking of certain comparable companies and the Company has filed an appeal before ITAT. | For Assessment year 2017-18, Transfer pricing adjustment amounting to INR 17,54,70,201 pertaining to payment of royalty by arbitrarily determining the arm’s length price (“ALP”) of the international transaction as against computed by MSL in accordance with the provisions of the Act read with the Income-tax Rules, 1962 (“Rules”) using TNMM Method and / or CUP. Further Transfer pricing adjustment amounting to INR 2,35,38,892 pertaining to manufacturing segment on account of cherry picking of certain comparable companies and the Company has filed an appeal before ITAT and the same is pending. |
8 | Income tax Department/Assessing Officer | 15-06-2022 | For Assessment year 2018-19, Transfer pricing adjustment amounting to INR 13,26,68,832 pertaining to payment of royalty by arbitrarily determining the arm’s length price (“ALP”) of the international transaction as against computed by MSL in accordance with the provisions of the Act read with the Income-tax Rules, 1962 (“Rules”) using TNMM Method and / or CUP. Further, transfer pricing adjustment amounting to INR 1,14,76,800 pertaining to manufacturing segment on account of cherry picking of certain comparable companies and the Company has filed an appeal before ITAT | For Assessment year 2018-19, Transfer pricing adjustment amounting to INR 13,26,68,832 pertaining to payment of royalty by arbitrarily determining the arm’s length price (“ALP”) of the international transaction as against computed by MSL in accordance with the provisions of the Act read with the Income-tax Rules, 1962 (“Rules”) using TNMM Method and / or CUP. Further, transfer pricing adjustment amounting to INR 1,14,76,800 pertaining to manufacturing segment on account of cherry picking of certain comparable companies and the Company has filed an appeal before ITAT and the same is pending. |
9 | Income tax Department/Assessing Officer | 29-08-2024 | For Assessment year 2020-21, Transfer pricing adjustment amounting to INR 30,59,67,825 pertaining to payment of royalty by arbitrarily determining the arm’s length price (“ALP”) of the international transaction as against computed by MSL in accordance with the provisions of the Act read with the Income-tax Rules, 1962 (“Rules”) using TNMM Method and / or CUP. Further, transfer pricing adjustment amounting to INR 1,54,75,557 pertaining to manufacturing segment on account of cherry picking of certain comparable companies and the Company has filed an appeal before ITAT | For Assessment year 2020-21, Transfer pricing adjustment amounting to INR 30,59,67,825 pertaining to payment of royalty by arbitrarily determining the arm’s length price (“ALP”) of the international transaction as against computed by MSL in accordance with the provisions of the Act read with the Income-tax Rules, 1962 (“Rules”) using TNMM Method and / or CUP. Further, transfer pricing adjustment amounting to INR 1,54,75,557 pertaining to manufacturing segment on account of cherry picking of certain comparable companies and the Company has filed an appeal before ITAT and the same is pending before ITAT |
10 | Income tax Department/Assessing Officer | 18-12-2024 | For Assessment year 2021-22, Transfer pricing adjustment amounting to INR 26,93,07,230 pertaining to payment of royalty by arbitrarily determining the arm’s length price (“ALP”) of the international transaction as against computed by MSL in accordance with the provisions of the Act read with the Income-tax Rules, 1962 (“Rules”) using TNMM Method and / or CUP. Further, transfer pricing adjustment amounting to INR 3,32,77,983 pertaining to manufacturing segment on account of cherry picking of certain comparable companies and the Company has filed an appeal before ITAT | For Assessment year 2021-22, Transfer pricing adjustment amounting to INR 26,93,07,230 pertaining to payment of royalty by arbitrarily determining the arm’s length price (“ALP”) of the international transaction as against computed by MSL in accordance with the provisions of the Act read with the Income-tax Rules, 1962 (“Rules”) using TNMM Method and / or CUP. Further, transfer pricing adjustment amounting to INR 3,32,77,983 pertaining to manufacturing segment on account of cherry picking of certain comparable companies and the Company has filed an appeal before ITAT and the same is pending before ITAT |
11 | Employees' State Insurance Corporation | 02-02-2006 | For Financial year 1994-1995 an order is issued by Dy. Director (Rev) of ESIC on 02.02.2006 for an amount of Rs. 53,039/-. | For Financial year 1994-1995 an order is issued by Dy. Director (Rev) of ESIC on 02.02.2006 for an amount of Rs. 53,039/-. The report is pending from ESI Court Gurgaon. |
12 | Employees' State Insurance Corporation | 02-02-2006 | For Financial year 1995-1996 an order is issued by Dy. Director (Rev) of ESIC on 02.02.2006 for an amount of Rs. 12,04,591/-. | For Financial year 1995-1996 an order is issued by Dy. Director (Rev) of ESIC on 02.02.2006 for an amount of Rs. 12,04,591/-. Re-inspection has been done and demand is reduced to Rs. 8,40,878 on 18.07.2016. The report is pending from ESI Court Gurgaon. |
13 | Employees' State Insurance Corporation | 20-02-2006 | For Financial year 1996-1997 an order is issued by Dy. Director (Rev) of ESIC on 20.02.2006 for an amount of Rs. 6,49,999/-. | For Financial year 1996-1997 an order is issued by Dy. Director (Rev) of ESIC on 20.02.2006 for an amount of Rs. 6,49,999/-. Re-inspection has been done and demand is reduced to Rs. 2,68.653 on 18.07.2016. The report is pending from ESI Court Gurgaon. |
14 | Employees' State Insurance Corporation | 20-02-2006 | For Financial year 1997-1998 an order is issued by Dy. Director (Rev) of ESIC on 20.02.2006 for an amount of Rs. 6,69,251/-. | For Financial year 1997-1998 an order is issued by Dy. Director (Rev) of ESIC on 20.02.2006 for an amount of Rs. 6,69,251/-. Re-inspection has been done and demand is reduced to Rs. 7,614/- on 18.07.2016. The report is pending from ESI Court Gurgaon. |
15 | Employees' State Insurance Corporation | 20-02-2006 | For Financial year 2001-2002 an order is issued by Dy. Director (Rev) of ESIC on 20.02.2006 for an amount of Rs. 19,321/-. | For Financial year 2001-2002 an order is issued by Dy. Director (Rev) of ESIC on 20.02.2006 for an amount of Rs. 19,321/-. Re-inspection has been done The report is pending from ESI Court Gurgaon. |
16 | Employees' State Insurance Corporation | 09-03-2018 | For Financial year 2013-2016 an order is issued by Dy. Director of ESIC on 09.03.2018 for an amount of Rs. 39,08,539/-. | For Financial year 2013-2016 an order is issued by Dy. Director of ESIC on 09.03.2018 for an amount of Rs. 39,08,539/-. The case is pending before the ESI Court Gurgaon. |
17 | Goods and service Tax, State tax Dehradun | 06-07-2024 | For Financial Year 2018-19, appeal has been filled against order of The J.C. (Appeals) State Tax, Dehradun for diffecernce in GSTR-3B & GSTR-2A. | Initial relevant details and documents submitted with GST department and awaiting reponse |