PCIT v. Wig Investments

461 ITR 117High Court2024#25067 most cited
3

judgments rely on this decision, according to BharatTax’s citation analysis of 348,615 Indian tax judgments — from 2025 to 2025.

Issues it is cited on

section 144c(1)section 144c(5)most appropriate methodarm's length pricetransfer pricing adjustmentsection 92casection 92cassociated enterprisedispute resolution panelsection 40(a)section 92section 144c

Judgments citing PCIT v. Wig Investments

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

In the result, all the three appeals of the assessee are allowed as indicated above and the appeal of Revenue is partly allowed

ITA 901/DEL/2017[2012-13]Status: DisposedITAT Delhi08 Oct 2025AY 2012-13

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri G.C. Srivastava, Spl. Counsel for the Department
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 14ASection 32Section 35Section 43B

…axed as capital gains and not as business. In the result ground No. 1 raised by the revenue is dismissed.” (emphasis supplied) The aforesaid decision of the Delhi Tribunal has recently been affirmed by the Hon’ble Delhi High Court in PCIT vs. Wig Investments: 461 ITR 117. The said decision is on all fours with the facts in the case of the appellant and squarely covers the present dispute. Having regard to the aforesaid submissions, the action of the assessing officer in treating the gains from sale and purchase of mutual funds as in the nature of “business income” is erroneous and cannot be sustained. Re: Princi…

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

In the result, all the three appeals of the assessee are allowed as indicated above and the appeal of Revenue is partly allowed

ITA 1024/DEL/2016[2011-12]Status: DisposedITAT Delhi08 Oct 2025AY 2011-12

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri G.C. Srivastava, Spl. Counsel for the Department
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 14ASection 32Section 35Section 43B

…axed as capital gains and not as business. In the result ground No. 1 raised by the revenue is dismissed.” (emphasis supplied) The aforesaid decision of the Delhi Tribunal has recently been affirmed by the Hon’ble Delhi High Court in PCIT vs. Wig Investments: 461 ITR 117. The said decision is on all fours with the facts in the case of the appellant and squarely covers the present dispute. Having regard to the aforesaid submissions, the action of the assessing officer in treating the gains from sale and purchase of mutual funds as in the nature of “business income” is erroneous and cannot be sustained. Re: Princi…

Vodafone Digilink Ltd., New Delhi vs. DCIT, New Delhi

In the result, appeal of the assessee Ground Nos 9 & 10 is allowed

ITA 1169/DEL/2014[2009-10]Status: DisposedITAT Mumbai12 Feb 2025AY 2009-10

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Percy J. Pardiwalla/wShriFor Respondent: Ms. Vatsala Jha (PCIT)
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 35ASection 36(1)(m)Section 37(1)Section 40Section 43(1)

…52 (Bombay). It is further submitted that the Special Leave Petition ('SLP') filed by the Revenue challenging the aforesaid judgment of the Bombay High Court has been dismissed by the Supreme Court in the case of PCIT v/s. L & T Valves Ltd. reported in (2024) 461 ITR 117 (SC). 5. 3. The Ld. AR argued that considering the foregoing facts and the judicial precedents on the subject, the assessee submits that the action of the TPO in considering the controlled transaction entered into between 'Virgin Enterprises Ltd. and "Virgin Mobile USA LLC' while benchmarking the transaction of payment of royalty is not in accor…

PCIT v. Wig Investments (461 ITR 117) — Cited in 3 Judgments | BharatTax