Motherson Sumi Infotech & Design Ltd. v. Assistant Commissioner of Income-tax

112 Taxmann.com 300Reported decision#18809 most cited
4

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2023 to 2024.

Issues it is cited on

section 92b(1)related party transactionbenchmarking analysistransactional net margin methodarms length pricesection 92bcomparable companiestnmmsection 92carm's length pricedispute resolution panelassociated enterprises

Judgments citing Motherson Sumi Infotech & Design Ltd. v. Assistant Commissioner of Income-tax

DCIT, NEW DELHI vs. M/S. SONY INDIA PVT. LTD., NEW DELHI

In the result, appeal filed by the assessee is partly allowed as indicated above and appeal filed by the revenue is dismissed

ITA 1166/DEL/2015[2010-11]Status: DisposedITAT Delhi30 Aug 2024AY 2010-11

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Shri Rajesh Kumar, CIT DR
Section 143Section 143(2)Section 143(3)Section 92C

…were given to us for its exclusion; hence, we are of the view that Persistent system has rightly been included as Comparable company by ld DRP and TPO. and not in sale of software products. Also in the case of Motherson Sumi infotech and Design ltd.. vs/ ACIT 112 Taxmann.com 300 (2019) again this company was held to be involved in software services only. The para 32 of the Hon’ble ITAT order is very pertinent and reproduced below for ready reference… 32. The Annual Report of this company is placed at pages 762 to 895 of the paper book. In its Profit and Loss account, sale of software services and products is at R…

SONY INDIA PRIVATE LIMITED,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME-TAX, NEW DELHI

In the result, appeal filed by the assessee is partly allowed as indicated above and appeal filed by the revenue is dismissed

ITA 1026/DEL/2015[2010-11]Status: DisposedITAT Delhi30 Aug 2024AY 2010-11

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Shri Rajesh Kumar, CIT DR
Section 143Section 143(2)Section 143(3)Section 92C

…were given to us for its exclusion; hence, we are of the view that Persistent system has rightly been included as Comparable company by ld DRP and TPO. and not in sale of software products. Also in the case of Motherson Sumi infotech and Design ltd.. vs/ ACIT 112 Taxmann.com 300 (2019) again this company was held to be involved in software services only. The para 32 of the Hon’ble ITAT order is very pertinent and reproduced below for ready reference… 32. The Annual Report of this company is placed at pages 762 to 895 of the paper book. In its Profit and Loss account, sale of software services and products is at R…

DELPHI AUTOMOTIVE SYSTEMS (P) LTD,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME-TAX, NEW DELHI

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

ITA 1361/DEL/2015[2010-11]Status: DisposedITAT Delhi09 Oct 2023AY 2010-11

Bench: Shri M. Balaganesh & Shri Anubhav Sharmaaptive Components India P. Ltd, Vs. Deputy Commissioner (Formerly Known As Delphi Of Income-Tax, Automotive Systems P. Ltd), Circle-7(1), P-24, Green Park Extension, New Delhi South Delhi, New Delhi-110016 (Appellant) (Respondent) Pan:Aaacd0226E

For Appellant: Sh. Neeraj Jain, AdvFor Respondent: Sh. Rajesh Kumar, CIT DR
Section 143(3)Section 144CSection 92CSection 92C(2)

…INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “I”: NEW DELHI BEFORE SHRI M. BALAGANESH, ACCOUNTANT MEMBER AND SHRI ANUBHAV SHARMA, JUDICIAL MEMBER Aptive Components India P. Ltd, Vs. Deputy Commissioner (formerly known as Delphi of Income-tax, Automotive Systems P. Ltd), Circle-7(1), P-24, Green Park Extension, New Delhi South Delhi, New Delhi-110016 (Appellant) (Respondent) PAN:AAACD0226E Assessee by : Sh. Neeraj Jain, Adv Mr. Abhishek Aggarwal, AR Sh. Ramit Katyal, AR Revenue by: Sh. Rajesh Kumar, CIT DR Date of Hearing 10/07/2023 Date of pronouncement 09/10/2023 O R D E R PER M. BALAGANESH, A. M.: 1. The appeal…

TPG SOFTWARE PVT. LTD.,DELHI vs. DCIT, CIRCLE-25(2), NEW DELHI

In the result, the appeal of the assessee is dismissed

ITA 6468/DEL/2018[2014-15]Status: FixedITAT Delhi11 Sept 2023AY 2014-15

Bench: Sh. Kul Bharatdr. B. R. R. Kumar

For Appellant: Sh. Vishal Kalra, AdvFor Respondent: Sh. Rajesh Kumar, CIT DR
Section 143(3)Section 144C(13)Section 234Section 271(1)(c)Section 92C(3)(c)

…m has rightly been included as Comparable company by Id DRP and TPO. Thus this company is clearly held to be involved in sale of software services only and not in sale of software products. Also in the case of Motherson Sumi infotech and Design Ltd. vs/ ACIT 112 Taxmann.com 300 (2019) again this company was held to be involved in software services only. The para 32 of the Hon'ble ITAT order is very pertinent and reproduced below for ready reference… 32. The Annual Report of this company is placed at pages 762 to 895 of the paper book. In its Profit and Loss account, sale of software services and products is at…

Motherson Sumi Infotech & Design Ltd. v. Assistant Commissioner of Income-tax (112 Taxmann.com 300) — Cited in 4 Judgments | BharatTax