IN THE ITAT MUMBAI
Piramal Healthcare Ltd.
V/s.
Assistant Commissioner of Income-tax (TDS)
IT Appeal Nos. 7789 to 7792 AND 7794 (Mum.) of 2011
[Assessment years 2007-08 to 2011-12]
May 9, 2012
ORDER
J. Sudhakar Reddy, Accountant Member – These four appeals by the assessee are directed against four separate orders of the CIT(Appeals)-14, Mumbai, all dated 12-10-2011, in relation to assessment years 2007-08 to 2011-12.
2. Since the appeals involve common grounds of appeal, same set of facts, they are taken up together and disposed of by this consolidated order, for the sake of convenience.
ITA No.7789/Mum/11 (AY 2007-08):
3. The brief facts of the case are that the assessee company is engaged in manufacturing, trading and distribution of drugs. On 05-09-2005, it entered into an Agreement with M/s. Zivon Marketing Services Pvt. Ltd., appointing the said firm as its ‘super stockist’. The responsibility of the said super stockist as per Agreement was that it would be responsible for getting stock of the manufactured products of the assessee company, for onward transmission to the market, through the retailer.
4. In pursuance of the said Agreement, the assessee company sold the manufactured product to M/s. Zivon Marketing Services P. Ltd. for its onwards sale in the open market. Various stages of trading/supply chain of the products manufactured by the company, to a customer, is depicted down below (as has been stated in the record of the case):
