Maruti Suzuki India Ltd. v. ACIT

173 TTJ 513Income Tax Appellate Tribunal2015#23113 most cited
3

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2019 to 2023.

Judgments citing Maruti Suzuki India Ltd. v. ACIT

Maruti Suzuki India Ltd., New Delhi vs. DCIT, New Delhi

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

ITA 961/DEL/2015[2010-11]Status: DisposedITAT Delhi09 Feb 2023AY 2010-11

Bench: Shri Shamim Yahya & Shri Kul Bharat[Assessment Year : 2010-11] Maruti Suzuki India Ltd., Vs Dcit, Plot No.1, Nelson Mandela Road, Circle-16(1), Vasant Kunj, New Delhi-110070. New Delhi. Pan-Aaacm0829Q Appellant Respondent [Assessment Year : 2010-11] Dcit, Vs Maruti Suzuki India Ltd., Circle-16(1), Plot No.1, Nelson Mandela Road, New Delhi. Vasant Kunj, New Delhi-110070. Pan-Aaacm0829Q Appellant Respondent Appellant By Shri Ajay Vohra, Sr.Adv., Shri Neeraj Jain, Adv. & Ms. Tejasvi Jain & Ms. Somya Jain, Ca Respondent By Shri G.C.Srivastava, Adv., Shri Kalrav Mehrotra, Adv. & Shri Mayank Patawari, Ca Date Of Hearing 11.11.2022 Date Of Pronouncement 09.02.2023

Section 143(3)Section 144CSection 144C(5)Section 43Section 43B

…, the R&D cess should also be considered as revenue expenditure. Further, he pointed out that the similar issue was decided in favour of the assessee by the decision of the Delhi Bench of the Tribunal in AY 2006-07 reported in Maruti Suzuki India Ltd. vs ACIT 173 TTJ 513 [AYs 2007- 08, 2008-09, 2009-10]. He further pointed out that the Department appeal filed against the order of Tribunal for AY 2006-07 was not admitted by the Hon’ble Delhi High Court in ITA No.381/Del/2016. Against the said order of High Court, the Department has not gone into appeal before Hon’ble Supreme Court on this issue. Hence, this issue…

DCIT, New Delhi vs. M/S. Maruti Suzuki India Ltd., New Delhi

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

ITA 1507/DEL/2015[2010-11]Status: DisposedITAT Delhi09 Feb 2023AY 2010-11

Bench: Shri Shamim Yahya & Shri Kul Bharat[Assessment Year : 2010-11] Maruti Suzuki India Ltd., Vs Dcit, Plot No.1, Nelson Mandela Road, Circle-16(1), Vasant Kunj, New Delhi-110070. New Delhi. Pan-Aaacm0829Q Appellant Respondent [Assessment Year : 2010-11] Dcit, Vs Maruti Suzuki India Ltd., Circle-16(1), Plot No.1, Nelson Mandela Road, New Delhi. Vasant Kunj, New Delhi-110070. Pan-Aaacm0829Q Appellant Respondent Appellant By Shri Ajay Vohra, Sr.Adv., Shri Neeraj Jain, Adv. & Ms. Tejasvi Jain & Ms. Somya Jain, Ca Respondent By Shri G.C.Srivastava, Adv., Shri Kalrav Mehrotra, Adv. & Shri Mayank Patawari, Ca Date Of Hearing 11.11.2022 Date Of Pronouncement 09.02.2023

Section 143(3)Section 144CSection 144C(5)Section 43Section 43B

…, the R&D cess should also be considered as revenue expenditure. Further, he pointed out that the similar issue was decided in favour of the assessee by the decision of the Delhi Bench of the Tribunal in AY 2006-07 reported in Maruti Suzuki India Ltd. vs ACIT 173 TTJ 513 [AYs 2007- 08, 2008-09, 2009-10]. He further pointed out that the Department appeal filed against the order of Tribunal for AY 2006-07 was not admitted by the Hon’ble Delhi High Court in ITA No.381/Del/2016. Against the said order of High Court, the Department has not gone into appeal before Hon’ble Supreme Court on this issue. Hence, this issue…

Nikon India Pvt. Ltd., Gurgaon vs. DCIT, Circle- 3(1), Gurgaon

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

ITA 6870/DEL/2018[2014-15]Status: DisposedITAT Delhi24 Jan 2019AY 2014-15

Bench: Shri R.K. Panda & Ms Suchitra Kambleassessment Year: 2014-15 Nikon India Pvt. Ltd., Vs. Dcit, Plot No.71, Sector-32, Circle-3(1), Institutional Area, Gurgaon. Gurgaon. Pan: Aaccn5100F (Appellant) (Respondent) Assessee By : Shri Vishal Kalra, Shri S.S. Tomar & Shri Ankit Shahni, Advocates Revenue By : Shri H.K. Choudhalry, Cit, Dr Date Of Hearing : 26.11.2018 Date Of Pronouncement : 24.01.2019 Order Per R.K. Panda, Am: This Appeal By The Assessee Is Directed Against The Order Dated 9Th October, 2018 Passed U/S 143(3) Read With Section 144C Of The It Act, 1961 For Assessment Year 2014-15. 2. Facts Of The Case, In Brief, Are That The Assessee Is A Company & Belongs To Nikon Group Of Cases Which Is Involved In A Broad Spectrum Of Business Centred On Precision Equipment, Imaging Products, Instruments & Other Business. The Activities Of The Nikon Group Are Carried Out Through The Following Divisions:- I) Precision Equipment Business, Ii) Imaging Products Business, Iii) Instruments Business, Iv) Other Businesses. 3. The Assessee Filed Its Return Of Income On 24.11.2014 Declaring Total Income Of Rs.66,47,37,700/-. The Assessing Officer Made A Reference U/S 92Ca(1) Of The It Act To Determine The Arm’S Length Price Of The International Transactions Entered Into By The Assessee With Its Aes During The F.Y. 2013-14. The Tpo, During The Course Of Tp Assessment Proceedings Observed That The Assessee Has Entered Into The Following International Transactions During The Year:- No. Nature Of Transaction Value (Inr) Method Applied 1. Purchase Of Goods, Promotional & 6,571,207,639 Rpm Other Supplies 2 Purchase Of Fixed Assets 7,049,548 Tnmm 3 Service Income 30,717,853 Tnmm 4 Warranty Reimbursements Received 69,937,244 Cup 5. Cost Reimbursements Received 2,619,750 Cup 6 Cost Reimbursements Paid 5,628,706 Cup

For Appellant: Shri Vishal KalraFor Respondent: Shri H.K. Choudhalry, CIT, DR
Section 143(3)Section 144CSection 92BSection 92C

…. (1992) 193 ITR 624 (Ker.); iii) DCM Benetton India Ltd. vs. CIT (2008) 173 Taxman 283 (Del); iv) Allied Motors (P) Ltd. vs. CIT (1997) 224 ITR 677 (SC); v) CIT vs. C.L. Gupta & Sons (2003) 259 ITR 513 (All); vi) Maruti Suzuki India Ltd. vs. Addl. CIT (2015) 173 TTJ 513 (Del-Trib.); vii) DCIT vs. Glaxo SmithKline Consumer Healthcare Ltd. (2007) 107 ITD 343 (Chd.)(SB); & viii) CIT vs. Modipon Ltd., ITA No.48 of 1999 (Del). 16. He, accordingly submitted that this ground raised by the assessee should be decided in favour of the assessee. 17. The ld. DR, on the other hand, strongly opposed this ground raised by the…

Maruti Suzuki India Ltd. v. ACIT (173 TTJ 513) — Cited in 3 Judgments | BharatTax