DENSO HARYANA PVT. LTD.,NEW DELHI vs. ADDL.CIT, SPECIAL RANGE- 3 , NEW DELHI

ITA 6690/DEL/2019Status: DisposedITAT Delhi28 July 2026AY 2015-1620 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal restored the issue of DTAA benefits on dividend distribution tax to the Assessing Officer to await the Supreme Court's final decision on similar matters. The Tribunal also admitted additional grounds for refund claims and directed the AO to adjudicate them afresh.

What were the facts?

The assessee company, Denso Haryana Private Limited, appealed against the CIT(A)'s orders concerning transfer pricing adjustments for intra-group services and purchase of fixed assets, and the eligibility for DTAA benefits on dividend distribution tax. The appeals covered assessment years 2013-14 to 2015-16.

What were the issues?

The key issues involved transfer pricing adjustments for intra-group services and fixed asset purchases, and the applicability of DTAA provisions to Dividend Distribution Tax.

Which sections of the Income-tax Act were involved?

Section 92CA,Section 92,Section 115-O,Section 90,Section 10(34),Section 237,Section 271(1)(c),Section 234A,Section 234B,Section 234C,Section 234D

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH ‘A’, NEW DELHI

Before: SHRI SATBEER SINGH GODARA & SHRI MANISH AGARWAL

For Appellant: Shri Himanshu S. Sinha, Adv, Shri Jainender Kataria, Adv
For Respondent: Shri Mahesh Kumar, CIT(DR)
Hearing: 04.06.2026

These assessee’s three appeals ITA Nos. 1250/De/2023, 5389 & 6690/Del/2019 for Assessment Years 2013-14 to 2015- 16, arise against the Commissioner of Income Tax(Appeals) (for short, “CIT(A)”), Delhi-44’s as many orders dated 29.03.2023, 16.04.2019 & 28.06.2019, passed in ITBA/APL/S/250/2022- 23/1051553964(1), order no. 99/2018-19/CIT(A)-44, 233/2018- 19/CIT(A)-44; assessment year wise respectively, involving proceedings u/s 143(3) r.w.s 144C(3) of the Income Tax Act, 1961; hereinafter referred

The order continues below.

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