IN THE ITAT MUMBAI BENCH ‘K’
Hindustan Unilever Ltd.
Versus
Additional Commissioner of Income-tax
IT APPEAL NO. 7868 (MUM.) OF 2010
[ASSESSMENT YEAR 2006-07]
DECEMBER 10, 2012
ORDER
Per Bench – This appeal preferred by the assessee, is directed against the final assessment order dated 7th October 2010, passed by the Addl. Commissioner of Income Tax, Range-I(1), Mumbai, in pursuance of the directions given by the Dispute Resolution Panel (for short “DRP”), for the quantum of assessment passed under section 143(3) r/w 144C of the Income Tax Act, 1961 (for short “the Act”) for assessment year 2006-07.
2. In grounds no.1 to 15, which also includes various sub-grounds, the assessee has challenged the transfer pricing adjustment of Rs. 368,79,26,000, on the international transaction values. The assessee, Hindustan Uniliver Ltd., in which, 51.55% stake is held by Uniliver PLC is India’s largest Fast Moving Consumer Goods Company (for short “FMGC”). The main business of the company is export and import of home and personal care products, beverages, export of rice and marine products, export and import of soap and toiletries. The assessee has also been paying royalty to Uniliver PLC on domestic and export sales. During the year, the assessee had made following international transactions with the Associate Enterprises (for short “A.Es”).
