How many judgments cite 16. In Nokia India (P) Ltd. v. Dy. CIT?

21 judgments on BharatTax cite 16. In Nokia India (P) Ltd. v. Dy. CIT (153 ITD 508), spanning 2016 to 2025.

Which sections of the Income Tax Act does 16. In Nokia India (P) Ltd. v. Dy. CIT come up under?

It is most often cited in judgments turning on Section 143(3), Section 270A, Section 274, Section 92B, Section 92C, Section 92CA(4).

16. In Nokia India (P) Ltd. v. Dy. CIT

153 ITD 508High Court2015#5604 most cited

What is 16. In Nokia India (P) Ltd. v. Dy. CIT authority for?

Incurring high advertisement and marketing expenses does not preclude the use of the Resale Price Method (RPM) for determining the Arm's Length Price (ALP) under transfer pricing provisions. The ratio of related party transactions (RPTs) calculation requires careful consideration of the numerator and denominator to accurately reflect transactions with associated enterprises.

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2025.

Also referred to as

Nokia India · 153 ITD 508 · 52 Taxmann.com 492 · advertisement marketing expenses · resale price method · RPM · arm's length price · ALP · related party transactions · RPT · transactional net margin method · TNMM

Also reported as

52 Taxmann.com 492

Sections most often in play

Section 143(3)Section 270A Section 274 Section 92B Section 92C Section 92CA(4)Section 92D

Issues it is cited on

resale price method tested party related party transaction working capital adjustment transactional net margin method benchmarking analysis comparable companies most appropriate method intangible assets section 92ca(3)arm's length price tnmm

Judgments citing 16. In Nokia India (P) Ltd. v. Dy. CIT

MASSIMO DUTTI INDIA PRIVATE LIMITED,GURGAON vs. ACIT, CIRCLE-1(1), GURGAON

In the result, the appeal of the Assessee is allowed

ITA 2252/DEL/2022[2018-19]Status: DisposedITAT Delhi08 Dec 2025AY 2018-19

Bench: Shri M. Balaganesh & Shri Vimal Kumarmassimo Dutti India Pvt. Ltd, Vs. Acit, Unit No. 1 (Office 1) 8Th Floor, Circle-1(1), Ambience Island, Nh-8, Gurgaon Gurugram, Hayana-122 002 (Appellant) (Respondent) Pan: Aajcm0103G Assessee By : Shri Ravi Sharma, Adv Ms. Shruti Khimta, Adv Ms. Kashish Gupta, Ca Revenue By: Shri S. K. Jadav, Cit Dr Date Of Hearing 11/09/2025 Date Of Pronouncement 08/12/2025

For Appellant: Shri Ravi Sharma, AdvFor Respondent: Shri S. K. Jadav, CIT DR

Section 143(3)Section 144C(5)Section 92C

…d substantial AMP, and other expenses, in relation to its turnover, and is therefore, not a simple distributor in terms of the requirement of using RPM, Ld. AR has rightly placed reliance on the decision reported in Nokia India Private Limited vs. DCIT (2015) 153 ITD 508 (Delhi-trib.) wherein it was held that the incurring of high advertisement and marketing expenses by the assessee vis-a-vis the other comparable companies does not in any manner affect the determination of ALP under the RPM. In the above decision it was held that, - The Id. DR vehemently argued against the application of RPM in the given circumst…

PANASONIC INDIA PRIVATE LTD.,GURGAON vs. NEAC, NEW DELHI

In the result, the appeal of the assessee is partly allowed

ITA 612/DEL/2021[2016-17]Status: DisposedITAT Delhi08 Oct 2025AY 2016-17

Bench: Shri C. N. Prasad & Shri M. Balaganeshpanasonic India Pvt. Ltd, Vs. Neac, 12Th Floor, Ambience New Delhi Corporate Office, Tower-2, Ambience Island, Gurgaon (Appellant) (Respondent) Pan: Aadcp9391B

For Appellant: Shri Kanchan Kaushal, AdvFor Respondent: Shri S. K. Jadav, CIT (DR)

Section 143(3)Section 144C(5)Section 92BSection 92C

…e Delhi High Court in the case of PCIT vs Matrix Cellular International Services Pvt Ltd in ITA 484 of 2017 dated 22-11- 2017 e) Decision of Delhi Tribunal in the case of Nokia India (P) Ltd vs DCIT in ITA Nos. 178 & 242/Del/2010 dated 31-10-2014 reported in 153 ITD 508 f) Decision of Delhi Tribunal in the case of Horiba India Pvt Ltd vs DCIT in ITA No. 6638/Del/2015 dated 18-04-2017 g) Decision of Delhi Tribunal in the case of Swarovski India P Ltd vs ACIT in ITA 5496 and 5621 (Delhi) of 2014 dated 10-02-2017 h) Decision of Delhi Tribunal in the case of DCIT vs Tianjin Tianshi India P Ltd in ITA 2847 (Delhi)…

PR. COMMISSIONER OF INCOME TAX-1, DELHI vs. D LIGHT ENERGY P. LTD.

The appeal is dismissed, alongwith all the pending

ITA/53/2025HC Delhi18 Mar 2025

Bench: HON'BLE CHIEF JUSTICE DEVENDRA KUMAR UPADHYAYA,HON'BLE MR. JUSTICE TUSHAR RAO GEDELA

For Appellant: Mr. Sanjay Kumar, Ms. Monica Benjamin and MsFor Respondent: Mr. Ved Jain, Mr. Nischay Kantoor and Ms

Section 143(2)Section 144C(2)Section 144C(5)Section 260ASection 92C

…le. In Nokia India (P) Ltd. v. Dy. Digitally Signed By:VINOD KUMAR Signing Date:18.03.2025 14:50:53 Signature Not Verified ITA 53/2025 Page 19 of 21 CIT, (2014) 52 taxmann.com 492/153 ITD 508 (Delhi), the Delhi bench of the ITAT held: “A close scrutiny of the above two sub-clauses along with the remaining sub-clauses of r. 10B(1)(b) makes it clear beyond doubt that RPM is best suited for determining ALP of an international transaction in the nature of purchase of goods from an AE which are resold as such to unrelated parties.…

PR. COMMISSIONER OF INCOME TAX- 2, DELHI vs. M/S. BURBERRY INDIA PVT. LTD.

ITA/471/2019HC Delhi24 Oct 2024

Bench: HON'BLE MR. JUSTICE VIBHU BAKHRU,HON'BLE DR. JUSTICE SWARANA KANTA SHARMA

Section 260ASection 92C

…ITA No.471/2019 Page 8 of 20 distributor on account of incurring substantial AMP expenses, was not justified. 25. The learned Tribunal relied upon its earlier decision in Nokia India (P) Ltd v. Dy CIT : (2014) 52 taxman.com 492/153 ITD 508 (Delhi) as well as the decision of this Court in Principal Commissioner of Incometax-6 v. Matrix Cellular International Services (P) Ltd : (2018) 90 taxman.com 54 (Delhi) in arriving at the aforesaid conclusion that RPM is the most appropriate method for benchmarking the international transaction in question. REASONS AND CONCLUSION 26.…

FARE PORTAL INDIA PRIVATE LIMITED,NEW DELHI vs. DCIT, CIRCLE-7(1), DELHI

In the result, the appeal of the assessee in ITA No

ITA 497/DEL/2022[2017-18]Status: DisposedITAT Delhi26 Jul 2024AY 2017-18

Bench: Shri G. S. Pannu & Shri Yogesh Kumar U.S.

For Appellant: Shri Himanshu S. SinhaFor Respondent: Shri Mahesh Shah

Section 143(3)Section 92CSection 92C(3)Section 92D

…1 Fare Portal India Pvt. Ltd. Vs. DCIT IN THE INCOME TAX APPELLATE TRIBUNAL [ DELHI BENCH: ‘I’ NEW DELHI ] BEFORE SHRI G. S. PANNU, VICE PRESIDENT AND SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER I.T.A. No. 497/DEL/2022 (A.Y 2017-18) Fare Portal India Pvt. Ltd., DCIT, Registered address: Vs. G–56, 03rd Floor, Circle : 7 (1) Green Park Main, New Delhi – 110 017. Communication address: 3 NPL Apartments, New Delhi. Vikas Puri, New Delhi – 110 018. PAN No. AAACF8769L (APPELLANT) (RESPONDENT) Assessee by : Shri Himanshu S. Sinha, Adv Department by: Shri Mahesh Shah, CIT (DR) & Sh. Kanv Bali, Sr. DR Date of Hearing…

KARCHER CLEANING SYSTEMS PVT. LTD.,NEW DELHI vs. ADDL. CIT SPL. RANGE-5, NEW DELHI

In the result, Appeal filed by the Assessee is partly allowed for statistical purposed

ITA 4986/DEL/2019[2014-15]Status: DisposedITAT Delhi18 Oct 2023AY 2014-15

Bench: Shri G. S. Pannu & Shri Yogesh Kumar U.S.

For Appellant: Shri Rohit TiwariFor Respondent: Shri Mrinal Kumar Das

Section 143(3)Section 144C(3)

…the assessee from its AEs were to be benchmarked and all the other functions carried out by the assessee having no nexus with the said import transactions were, thus, not relevant for the said benchmarking analysis.” 19. This Tribunal in Nokia India Pvt. Ltd 153 ITD 508 has held that incurring of high advertisement and marketing expenses by the 11 Karcher Cleaning Systems, ND assessee vis-a-vis the other comparable companies does not in any manner affect the determination of ALP under RPM. 20. Similar view was taken by the Pune Bench of the Tribunal in ITA No. 235/PUN/2013. 21. Considering the facts of the cas…

M/S CELIO FUTURE FASHION PRIVATE LIMITED,MUMBAI vs. ADDL/JT/CIT/DY/ASSTT/ITO/NFAC, DELHI, DELHI

In the result, the appeal by the assessee is partly allowed for statistical purposes

ITA 741/MUM/2022[2017-18]Status: DisposedITAT Mumbai08 Sept 2023AY 2017-18

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Sumant ChadhaFor Respondent: Shri Pravin Salunkhe

Section 115BSection 143(3)Section 144BSection 144C(13)Section 144C(5)Section 144C(8)Section 69CSection 920Section 92C

…refore, not a simple distributor in terms of the requirement of using RPM. Now we shall proceed to examine the law applicable these facts. M/s. Celio Future Fashion Pvt. Ltd. ITA no.741/Mum./2022 16. In Nokia India (P) Ltd. v. Dy. CIT[2014] 52 taxmann.com 492/153 ITD 508 (Delhi), the Delhi bench of the ITAT held that,- 9. Sub-clause (i) of clause (b) of Rule 10B(1) deals with identifying the price at which the goods purchased from an AE is resold. Sub-clause (ii) of clause (b) of Rule 10B(1) talks of reducing the amount of normal gross profit margin of comparable uncontrolled transactions from such resale price o…

KARCHER CLEANING SYSTEMS PVT. LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 6507/DEL/2016[2012-13]Status: DisposedITAT Delhi25 May 2022AY 2012-13

Bench: Shri N.K. Billaiya & Shri Yogesh Kumar U.S

For Appellant: Shri Rohit Tiwari, AdvFor Respondent: Shri Mrinal Kumar Das, Sr. DR

Section 143(3)

…y the assessee from its AEs were to be benchmarked and all the other functions carried out by the assessee having no nexus with the said import transactions were, thus, not relevant for the said benchmarking analysis. 19. This Tribunal in Nokia India Pvt Ltd 153 ITD 508 has held that incurring of high advertisement and marketing expenses by the assessee vis-a-vis the other comparable companies does not in any manner affect the determination of ALP under RPM. 20. Similar view was taken by the Pune Bench of the Tribunal in ITA No. 235/PUN/2013. 21. Considering the facts of the case in totality, we have no hesi…

DCIT 3(1)(1), MUMBAI vs. DIESEL FASHION INDIA RELIANCE PVT. LTD., MUMBAI

Accordingly it is to be dismissed as such

ITA 2931/MUM/2019[2013-14]Status: DisposedITAT Mumbai04 Mar 2022AY 2013-14

Section 143(3)

…d other expenses, in relation to its turnover, and is therefore, not a simple distributor in terms of the requirement of using RPM. Now we shall proceed to examine the law applicable these facts. 16. In Nokia India (P) Ltd. v. Dy. CIT[2014] 52 taxmann.com 492/153 ITD 508 (Delhi), the Delhi bench of the ITAT held that; “......A close scrutiny of the above two sub-clauses along with the remaining sub-clauses of rule 10B(1 b) makes it clear beyond doubt that RPM is best suited for determining ALP of an international transaction in the nature of purchase of from an AE which are resold as such to unrelated parties. Or…

FUJITSU INDIA PVT. LTD.,GURGAON vs. ACIT, CIRCLE-9(2), NEW DELHI

The appeal of the assessee is partly allowed

ITA 7363/DEL/2018[2014-15]Status: DisposedITAT Delhi23 Nov 2021AY 2014-15

Bench: Shri Kul Bharat & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri K. M. Gupta, AdvocateFor Respondent: Shri Surendra Pal [CIT] –

Section 143(3)Section 144CSection 234ASection 274Section 27i

…nal transactions in case of distribution of marketing activities by relied upon the decision rendered by Hon'ble Mumbai High Court in CIT v. L'oreal India (P.) Ltd. [2015] 53 taxmann.com 432 decisions of the Tribunal in Nokia India (P.) Ltd. v. Dy. CIT [2015] 153 ITD 508/[2014] 53 taxmann.com 492 (Delhi) and Mattel Toys (I.)(P.) Ltd. v. Dy. CIT [2013] 34 taxmann.com 203/[2013] 144 ITD 76 (Mum. - Trib.) and decided the issue in favour of the assessee by returning following findings :— "14. From the aforesaid decision it is quite ostensible that in case of a distributor, wherein the goods are purchased from AE and…

DEPUTY COMMISSIONER OF INCOME TAX -14(1)(2), MUMBAI vs. CITICORP SERVICES INDIA LIMITED , MUMBAI

In the result, appeal of the Revenue is partly allowed and appeal of the assessee is dismissed

ITA 4609/MUM/2017[2010-11]Status: DisposedITAT Mumbai20 Jul 2021AY 2010-11

Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘K‘ BENCH MUMBAI BEFORE: SHRI SAKTIJIT DEY, JUDICIAL MEMBER & SHRI M.BALAGANESH, ACCOUNTANT MEMBER The Dy. Commissioner of Vs. M/s. Citicorp Services India Income Tax-14(1)(2) Ltd., Room No. 470, 4th Floor Citibank Centre, Aayakar Bhavan Plot No.C-61, Bandra Kurla Maharshi Karve Road Complex, Bandra East Mumbai – 400 020 Mumbai – 400 051 PAN/GIR No.AADCC6705C (Appellant) .. (Respondent) M/s. Citicorp Services Vs. The Dy. Commissioner of India Ltd., Income Tax-14(1)(2) Room No. 470, 4th Floor First International 8th Financial Centre, Aayakar Bhavan Floor, Plot Nos. C-54 Mah…

BROTHER INTERNATIONAL (INDIA) PRIVATE LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX 15(1)(2) (EARLIER THE INCOME TAX OFFICER 10(3)(1), MUMBAI

In the result, the appeal filed by the assessee is partly allowed

ITA 5075/MUM/2017[2010-11]Status: DisposedITAT Mumbai13 Jan 2020AY 2010-11

Bench: Shri Vikas Awasthy () & Shri N.K. Pradhan () Assessment Year: 2010-11 Acit-15(1)(2), M/S Brother International Room No. 483A, 4Th Floor, Vs. (India) Pvt. Ltd., Aayakar Bhavan, M.K. Road, 703/704, Powai Plaza, Mumbai-400020. Hiranandani Business Park, Powai, Mumbai-400076. Pan No. Aadcb0263E Appellant Respondent Assessment Year: 2010-11 M/S Brother International The Assistant (India) Pvt. Ltd., Vs. Commissioner Of Income Unit No. 408, 4Th Floor, B- Tax, 15(1)(2), [Earlier The Wing, 215 Atrium, Andheri Income Tax Officer- Kurla Road, Andheri (East), 10(3)(1)], Room No. 483A, Mumbai-400059. 4Th Floor, Aayakar Bhavan, M.K. Road, Mumbai- 400020. Pan No. Aadcb0263E Appellant Respondent

For Appellant: Mr. Ketan Ved, Mr. Pawan SharmaFor Respondent: Mr. Ashish Heliwal, DR

Section 143(3)Section 92C(3)

…ibution or marketing activities when goods are M/s Brother International (India) Pvt. Ltd. without any further processing, then, RPM (resale price method) is most appropriate method to determine ALP of said transaction. In Nokia India (P.) Ltd. v. DCIT (2014) 153 ITD 508 (Delhi-Trib.), it is held that RPM is best suited for determining ALP of an international transaction in nature of purchase of goods from an AE which are resold as such to unrelated parties and it pre-supposes no or insignificant value addition to the goods purchased from foreign AE. In Mattel Toys (I) (P.) Ltd. v. DCIT (2014) 30 ITR (T) 283 (Mum…

ASST CIT 15(1)(2), MUMBAI vs. BROTHER INTERNATIONAL (INDIA) P.LTD, MUMBAI

In the result, the appeal filed by the assessee is partly allowed

ITA 4750/MUM/2017[2010-11]Status: DisposedITAT Mumbai13 Jan 2020AY 2010-11

For Appellant: Mr. Ketan Ved, Mr. Pawan SharmaFor Respondent: Mr. Ashish Heliwal, DR

Section 143(3)Section 92C(3)

ECOLAB FOOD SAFETY & HYGIENE SOLUTIONS P.LTD,MUMBAI vs. ASST CIT 9(2)(2), MUMBAI

In the result, appeal of the assessee is allowed for statistical purposes

ITA 1715/MUM/2017[2012-13]Status: DisposedITAT Mumbai26 Jul 2019AY 2012-13

Bench: Shri M.Balaganesh, Am & Shri Ravish Sood, Jm M/S. Ecolab Food Safety & Vs. Assistant Commissioner Of Hygiene Private Limited Income Tax – 9(2)(2), 215, Atrium, A-Wing Room No.665A, Unit No.808, Andheri-Kurla Aaykar Bhavan Road, Andheri (E) Mk Road, Mumbai - 400020 Mumbai – 400 059 Pan/Gir No.Aabce7541C (Appellant) .. (Respondent)

Section 143(3)Section 144C(5)

…a pure trader, and there was no value addition made before re-selling the particular products (i.e. the SIM cards), its consequent finding that RPM is the Most Appropriate Method, is irreproachable. In Nokia India (P) Ltd. v. Dy. CIT[2014] 52 taxmann.com 492/153 ITD 508 (Delhi), the Delhi bench of the ITAT held: "A close scrutiny of the above two sub-clauses along with the remaining sub-clauses of r. 10B(1)(b) makes it clear beyond doubt that RPM is best suited for determining ALP of an international transaction in the nature of purchase of goods from an AE which are resold as such to unrelated parties. Ordinari…

VIDEOJET TECHNOLOGIES (I) P. LTD,NAVI MUMBAI vs. ASST CIT CIR 10(3), MUMBAI

In the result, appeal of the assessee is allowed

ITA 6956/MUM/2012[2008-09]Status: DisposedITAT Mumbai28 May 2019AY 2008-09

Bench: Shri G.S.Pannu & Shri Ravish Soodm/S Videojet Technologies Vs. Acit, Circle-10(3), Mumbai (I) Pvt. Limited, Unit 101 & 102, Rupa Solitaire, Building No.A-1, Sector-1, Millennium Business Park, Mahape, Navi Mumbai-400710 Pan No.Aaacw0731 B (Appellant) .. (Respondent)

Section 143(3)Section 92C(2)

CELIO FUTURE FASHION P.LTD,MUMBAI vs. ASST CIT 9(2)(1), MUMBAI

In the result, the appeal of the assessee is treated as

ITA 1928/MUM/2016[2011-12]Status: DisposedITAT Mumbai15 Mar 2019AY 2011-12

Bench: Shri B.R. Baskaran & Shri Amarjit Singhassessment Year : 2011-12 M/S. Celio Future Fashion Private Limited, (Formerly Known As Celio Future Fashion), The Assistant Commissioner Vs. A Wing, Unit No. 301 & 302, Of Income Tax-9(2)(1), Near Graham Firth Compound, Mumbai Opposite Western Express Highway, Goregaon (East), Mumbai [Pan : Aadcc3844J]

For Appellant: Shri Niraj Sheth &For Respondent: Shri Purushottam Tripuri, CIT-DR

Section 143(3)

…d other expenses, in relation to its turnover, and is therefore, not a simple distributor in terms of the requirement of using RPM. Now we shall proceed to examine the law applicable these facts. 16. In Nokia India (P) Ltd. v. Dy. CIT[2014] 52 taxmann.com 492/153 ITD 508 (Delhi), the Delhi bench of the ITAT held that,- 9. Sub-clause (i) of clause (b) of Rule 10B(1) deals with identifying the price at which the goods purchased from an AE is resold. Sub-clause (ii) of clause (b) of Rule 10B(1) talks of reducing the amount of normal gross profit margin of comparable uncontrolled transactions from such resale price o…

BURBERRY INDIA PVT. LTD.,NEW DELHI vs. ITO, WARD- 5(2), NEW DELHI

In the result, both the appeals of the assessee are allowed

ITA 7684/DEL/2017[2013-14]Status: DisposedITAT Delhi22 Jun 2018AY 2013-14

Bench: Shri Prashant Maharishi & Shri K.N. Chary

Section 92

…ever, recorded that the assessee has incurred substantial AMP, and other expenses, in relation to its the requirement of using RPM. Now we shall proceed to examine the law applicable these facts. 16. In Nokia India (P) Ltd. v. Dy. CIT[2014] 52 taxmann.com 492/153 ITD 508 (Delhi), the Delhi bench of the ITAT held that,- 9. Sub-clause (i) of clause (b) of Rule 10B(1) deals with identifying the price at which the goods purchased from an AE is resold. Sub-clause (ii) of clause (b) of Rule 10B(1) talks of reducing the amount of normal gross profit margin of comparable uncontrolled transactions from such resale price o…

BURBERRY INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, both the appeals of the assessee are allowed

ITA 758/DEL/2017[2012-13]Status: DisposedITAT Delhi22 Jun 2018AY 2012-13

Bench: Shri Prashant Maharishi & Shri K.N. Chary

Section 92

PIPAL RESEARCH ANALYTICS AND INFORMATION SERVICES INDIA PVT. LTD.,GURGAON vs. ITO, NEW DELHI

In the result the appeal of the assessee is partly allowed

ITA 6374/DEL/2012[2008-09]Status: DisposedITAT Delhi18 Jun 2018AY 2008-09

Bench: Shri Amit Shukla & Shri O.P. Kant

For Appellant: Shri Anubhav Rastogi, AdvFor Respondent: Shri S.K. Ambastha, CIT,DR

Section 10ASection 143(3)Section 144CSection 43Section 438Section 92C(2)

…is. In support he relied upon various decisions:- - Assistant Commissioner of Income-tax, Circle 3 (1), New Delhi v. Convergys India Service (P.) Ltd.(55 Taxmann.com 30) - Nokia India (P.) Ltd. v. Deputy Commissioner of Income-tax, Circle -13(1), New Delhi (52 Taxmann.com 492) - Deputy Commissioner of Income-tax- 6(3),Mumbai v. Matrix India Asset Advisors (P.) Ltd.(49 Taxmann.com 151) - Assistant Commissioner of Income-tax, 11 (1), Mumbai v. Zee Entertainment Enterprises Ltd.*(51 Taxmann.com 231) - Deputy Commissioner of Income-tax, Circle 12 (1), Bangalore v. Misys Software (I) (P.) Ltd.*(56 taxmann.com 332…

M/S. TERADATA INDIA PRIVATE LIMITED,GURGAON vs. DCIT, GURGAON

In the result ground No. 6 of the appeal of the assessee is allowed with above direction

ITA 1833/DEL/2014[2009-10]Status: DisposedITAT Delhi11 May 2017AY 2009-10

Bench: Shri I. C. Sudhir & Shri Prashant Maharishiteradata India Pvt. Ltd, Vs. Dcit, Unit No. 304, 3Rd Floor, Tower- Circle-Ii, 4A, Gurgaon Gurgaon Pan: Aacct6715A (Appellant) (Respondent)

For Appellant: Shri Percy PardiwalaFor Respondent: Shri Neeraj Kumar

Section 10ASection 143(3)(ii)Section 92C

…Teradata India Private Limited V DCIT ITA No 1833/Del/2014 AY 2009-10 INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “I-1”: NEW DELHI BEFORE SHRI I. C. SUDHIR, JUDICIAL MEMBER AND SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER Teradata India Pvt. Ltd, Vs. DCIT, Unit No. 304, 3rd Floor, Tower- Circle-II, 4A, Gurgaon Gurgaon PAN: AACCT6715A (Appellant) (Respondent) Assessee by : Shri Percy Pardiwala, Senior Advocate Shri Bharat Jonarthnan, Advocate Revenue by: Shri Neeraj Kumar, Senior Departmental representative Date of Hearing 08/03/2017 Date of pronouncement 11/05/2017 O R D E R PER PRASHANT MAHARISHI, A. M. 1. This i…

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