Perot Systems TSI (India) Ltd. v. DCIT

37 SOT 358Income Tax Appellate Tribunal2010#2110 most cited

What is Perot Systems TSI (India) Ltd. v. DCIT authority for?

Interest-free loans given to 100% foreign subsidiaries are not accepted as quasi-capital, and the arm's length price of such loans can be determined and added to total income.

55

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2016 to 2026.

Also referred to as

Perot Systems TSI v. DCIT · 37 SOT 358 · ITAT Delhi · interest free loans · foreign subsidiaries · quasi equity · arm's length price · transfer pricing · loan transactions

Also reported as

144 ITD 2655 ITR (Trib) 106

Sections most often in play

Section 143(3)Section 133ASection 148Section 271(1)(c)Section 147Section 10AASection 10CSection 10D

Issues it is cited on

section 80iesection 75section 10basection 35(1)(iv)section 92(1)section 100interest on outstanding receivablesprofit split methodsection 10(2a)bright line testresale price methodsection 36(l)(va)

Judgments citing Perot Systems TSI (India) Ltd. v. DCIT

Bombay Rayon Holding Ltd., Mumbai vs. Addl/Jt/Dy/CIT/Asstt. ITO, National E-Assessment Centre, Delhi

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

ITA 1208/MUM/2021[2016-17]Status: DisposedITAT Mumbai01 Feb 2023AY 2016-17

Bench: Shri B.R. Baskaran (Am) & Shri Rahul Chaudhary (Jm)

Section 143(3)Section 234ASection 234B

…of case laws. The assessee’s plea that it was for business expediency and that it was out of own funds have been correctly rejected by the authorities below. In this regard, the decision of ITAT Delhi Bench in the case of Perot Systems TSI (India) Ltd. [2010] 37 SOT 358 (Delhi) is relevant. In that case, the ITAT did not accept the arguments of commercial expediency as well as the reliance on the Hon’ble Supreme Court in the case of SA Builders. Similar view has been taken in other decisions referred above including Tata Autocomp systems Ltd 21 taxmann.com 6 (Mum.) vide order dated 30/04/2012. This decision was a…

Wns Global Services P. Ltd., Mumbai vs. Addl/Jt/Dy/Asstt/CIT/ITO, Nationa Faceless Assessment Centre, Dilhi

In the result, appeal filed by the assessee is allowed

ITA 1259/MUM/2021[2016-17]Status: DisposedITAT Mumbai09 Dec 2022AY 2016-17

Bench: Shri Vikas Awasthy & Shri Gagan Goyalwns Global Services Pvt. Ltd., Pl 10, Gate No.4, Godrej & Boyce Complex, Pirojshanagar, Lbs Marg, Vikhroli (West), Mumbai-400079. Pan: Aaacw2598L ...... Appellant Vs.. Addl./Jt/Dy./Acit/Ito/Nfac, Room No. 455, Circle-14(3)(1), Mumbai. ..... Respondent Appellant/Assessee By : Sh. Porus Kaka, Sr. Adv. & Sh. Manish Kant Respondent/Revenue By : Sh. Jasdeep Singh, Cit-Dr

For Appellant: Sh. Porus Kaka, Sr. Adv. &For Respondent: Sh. Jasdeep Singh, CIT-DR
Section 143(3)Section 144C(13)Section 92B

…WNS Global Services Pvt. Ltd. "Since benefit of tolerance range of +/-3% can be availed even in case of single price determined as ALP. Reliance is placed on Hon'ble Mumbai ITAT's rulings in the following cases: DDIT vs. Development Bank of Singapore [(2013) 144 ITD 265 (Mumbai)] and DDIT vs. Sonata Software Ltd. {ITA 594/Mum/2017 & ITA 721/Mum/2017] Action Plan 8-10 of OECD's Base Erosion and Profit Shifting Project where, in the context of hard to value intangibles. states that if the actual outcomes do not result in reducing/ increasing the compensation of such intangibles by more than 20% of the compensation…

DCIT, Circle- 7(1), New Delhi vs. Dabur India Ltd., New Delhi

In the result, all these appeals are allowed for statistical purposes

ITA 183/DEL/2018[2011-12]Status: DisposedITAT Delhi20 Sept 2022AY 2011-12
For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Shri Mahesh Shah, CIT DR
Section 801BSection 92C

…t rupee denominated loans. 82.20 We further find merit in the argument of the ld. Counsel that the Revenue /TPO himself in the case of Perot Systems TSI (India) Ltd. Vs. DCIT (2010-TIOL-51-ITAT-Del.) and in the case of DDIT vs. Development Bank of Singapore: 144 ITD 265 (Mum), has applied LIBOR rate for benchmarking of international transaction of loans undertaken with the AE. It is the settled law that the Revenue has to be consistent in its approach and it is not open to the Revenue to take an inconsistent stand in the case of different assessee. [Ref. Kaumudini Narayan Dalai: 249 ITR 219 (SC) and Berger Paint…

DCIT, Circle-7(1), New Delhi vs. Dabur India Ltd., New Delhi

In the result, all these appeals are allowed for statistical purposes

ITA 7431/DEL/2017[2010-11]Status: DisposedITAT Delhi20 Sept 2022AY 2010-11
For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Shri Mahesh Shah, CIT DR
Section 801BSection 92C

…t rupee denominated loans. 82.20 We further find merit in the argument of the ld. Counsel that the Revenue /TPO himself in the case of Perot Systems TSI (India) Ltd. Vs. DCIT (2010-TIOL-51-ITAT-Del.) and in the case of DDIT vs. Development Bank of Singapore: 144 ITD 265 (Mum), has applied LIBOR rate for benchmarking of international transaction of loans undertaken with the AE. It is the settled law that the Revenue has to be consistent in its approach and it is not open to the Revenue to take an inconsistent stand in the case of different assessee. [Ref. Kaumudini Narayan Dalai: 249 ITR 219 (SC) and Berger Paint…

Dabur India Ltd., New Delhi vs. DCIT, Circle-7(1), New Delhi

In the result, all these appeals are allowed for statistical purposes

ITA 7253/DEL/2017[2011-12]Status: DisposedITAT Delhi20 Sept 2022AY 2011-12
For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Shri Mahesh Shah, CIT DR
Section 801BSection 92C

…t rupee denominated loans. 82.20 We further find merit in the argument of the ld. Counsel that the Revenue /TPO himself in the case of Perot Systems TSI (India) Ltd. Vs. DCIT (2010-TIOL-51-ITAT-Del.) and in the case of DDIT vs. Development Bank of Singapore: 144 ITD 265 (Mum), has applied LIBOR rate for benchmarking of international transaction of loans undertaken with the AE. It is the settled law that the Revenue has to be consistent in its approach and it is not open to the Revenue to take an inconsistent stand in the case of different assessee. [Ref. Kaumudini Narayan Dalai: 249 ITR 219 (SC) and Berger Paint…

Dabur India Ltd., New Delhi vs. DCIT, Circle- 7(1), New Delhi

In the result, all these appeals are allowed for statistical purposes

ITA 7154/DEL/2017[2010-11]Status: DisposedITAT Delhi20 Sept 2022AY 2010-11
For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Shri Mahesh Shah, CIT DR
Section 801BSection 92C

…t rupee denominated loans. 82.20 We further find merit in the argument of the ld. Counsel that the Revenue /TPO himself in the case of Perot Systems TSI (India) Ltd. Vs. DCIT (2010-TIOL-51-ITAT-Del.) and in the case of DDIT vs. Development Bank of Singapore: 144 ITD 265 (Mum), has applied LIBOR rate for benchmarking of international transaction of loans undertaken with the AE. It is the settled law that the Revenue has to be consistent in its approach and it is not open to the Revenue to take an inconsistent stand in the case of different assessee. [Ref. Kaumudini Narayan Dalai: 249 ITR 219 (SC) and Berger Paint…

The Dy. CIT, Gandhinagar Circle, Gandhinagar vs. M/S. Kalparatru Power Transmission Limited, Gandhinagar

Appeal of the assessee is dismissed

ITA 2853/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad06 Jul 2022AY 2012-13
For Appellant: Shri Milin Mehta, A.RFor Respondent: Shri Mohd Usman, CIT/DR
Section 143(3)Section 250(6)Section 92C

…0. Our attention was drawn to the contents of the said decision which was placed before us at Paper Book page no. 400 to 436. Taking us to Para 14 & 15 of the said decision, it was pointed out that in the case of Perot System TSI (India) Ltd vs Dy. CIT (2010) 37 SOT 358 (Delhi) identical issue was discussed and it was pointed out that the argument of loan being I.T.A No. 2471 & 2853/Ahd/2017 & Ors. A.Y. 2012-13 & 2013-14 Page No 6 Kalpataru Power Transmission Ltd. . vs. DCIT quasi capital in nature was rejected on facts since there was no material on record to establish so. From Para 15 of the order, it was poin…

Kalpataru Power Transmission Ltd., Gandhinagar vs. The Dy. CIT, Gandhinagar Circle, Gandhinagar

Appeal of the assessee is dismissed

ITA 2472/AHD/2017[2013-14]Status: DisposedITAT Ahmedabad06 Jul 2022AY 2013-14
For Appellant: Shri Milin Mehta, A.RFor Respondent: Shri Mohd Usman, CIT/DR
Section 143(3)Section 250(6)Section 92C

…0. Our attention was drawn to the contents of the said decision which was placed before us at Paper Book page no. 400 to 436. Taking us to Para 14 & 15 of the said decision, it was pointed out that in the case of Perot System TSI (India) Ltd vs Dy. CIT (2010) 37 SOT 358 (Delhi) identical issue was discussed and it was pointed out that the argument of loan being I.T.A No. 2471 & 2853/Ahd/2017 & Ors. A.Y. 2012-13 & 2013-14 Page No 6 Kalpataru Power Transmission Ltd. . vs. DCIT quasi capital in nature was rejected on facts since there was no material on record to establish so. From Para 15 of the order, it was poin…

Kalpataru Power Transmission Ltd., Gandhinagar vs. The Dy. CIT, Gandhinagar Circle, Gandhinagar

Appeal of the assessee is dismissed

ITA 2471/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad06 Jul 2022AY 2012-13
For Appellant: Shri Milin Mehta, A.RFor Respondent: Shri Mohd Usman, CIT/DR
Section 143(3)Section 250(6)Section 92C

…0. Our attention was drawn to the contents of the said decision which was placed before us at Paper Book page no. 400 to 436. Taking us to Para 14 & 15 of the said decision, it was pointed out that in the case of Perot System TSI (India) Ltd vs Dy. CIT (2010) 37 SOT 358 (Delhi) identical issue was discussed and it was pointed out that the argument of loan being I.T.A No. 2471 & 2853/Ahd/2017 & Ors. A.Y. 2012-13 & 2013-14 Page No 6 Kalpataru Power Transmission Ltd. . vs. DCIT quasi capital in nature was rejected on facts since there was no material on record to establish so. From Para 15 of the order, it was poin…

DCIT 16 (1), Mumbai vs. Tv 18 Braodcast Limited, Mumbai

In the result, the appeal filed by the Assessing Officer is dismissed in the terms indicated above

ITA 2502/MUM/2021[2012-13]Status: DisposedITAT Mumbai30 May 2022AY 2012-13
Section 143(3)Section 92F

…reasoning, without an independent analysis of the provisions of the Act and the rules”, the same seems to be the position with regard to “quasi capital”. There are several decisions of this Tribunal, including in the cases of Perot Systems TSI Vs DCIT [(2010) 130 TTJ 685 (Del)]., Micro Inks Ltd Vs ACIT [(2013) 157 TTJ 289 (Ahd)], Four Soft Pvt Ltd Vs DCIT [ (2014)149 ITD 732 (Hyd)], Prithvi Information Solutions Pvt Ltd Vs ACIT [(2014) 34 ITR (Tri) 429 (Hyd)] , which refer to the concept of „quasi capital‟ but none of these decisions throws any light on what constitutes „quasi capital‟ in the context of transfer…

ACIT -Cir 16(1), Mumbai vs. Tv 18 Braodcast Limited, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 2501/MUM/2021[2013-14]Status: DisposedITAT Mumbai30 May 2022AY 2013-14
Section 143(3)Section 92F

…reasoning, without an independent analysis of the provisions of the Act and the rules”, the same seems to be the position with regard to “quasi capital”. There are several decisions of this Tribunal, including in the cases of Perot Systems TSI Vs DCIT [(2010) 130 TTJ 685 (Del)]., Micro Inks Ltd Vs ACIT [(2013) 157 TTJ 289 (Ahd)], Four Soft Pvt Ltd Vs DCIT [ (2014)149 ITD 732 (Hyd)], Prithvi Information Solutions Pvt Ltd Vs ACIT [(2014) 34 ITR (Tri) 429 (Hyd)] , which refer to the concept of „quasi capital‟ but none of these decisions throws any light on what constitutes „quasi capital‟ in the context of transfer…

Tv 18 Broadcast Ltd, Mumbai vs. ACIT Cir 16(1), Muimbai

In the result, appeal of the Revenue is dismissed

ITA 1976/MUM/2021[2013-14]Status: DisposedITAT Mumbai30 May 2022AY 2013-14
Section 143(3)Section 92F

…reasoning, without an independent analysis of the provisions of the Act and the rules”, the same seems to be the position with regard to “quasi capital”. There are several decisions of this Tribunal, including in the cases of Perot Systems TSI Vs DCIT [(2010) 130 TTJ 685 (Del)]., Micro Inks Ltd Vs ACIT [(2013) 157 TTJ 289 (Ahd)], Four Soft Pvt Ltd Vs DCIT [ (2014)149 ITD 732 (Hyd)], Prithvi Information Solutions Pvt Ltd Vs ACIT [(2014) 34 ITR (Tri) 429 (Hyd)] , which refer to the concept of „quasi capital‟ but none of these decisions throws any light on what constitutes „quasi capital‟ in the context of transfer…

Tv 18 Broadcast Ltd, Mumbai vs. ACIT 16(1), Mumbai

In the result, the appeal filed by the Assessing Officer is dismissed in the terms indicated above

ITA 1975/MUM/2021[2012-13]Status: DisposedITAT Mumbai30 May 2022AY 2012-13
Section 143(3)Section 92F

…reasoning, without an independent analysis of the provisions of the Act and the rules”, the same seems to be the position with regard to “quasi capital”. There are several decisions of this Tribunal, including in the cases of Perot Systems TSI Vs DCIT [(2010) 130 TTJ 685 (Del)]., Micro Inks Ltd Vs ACIT [(2013) 157 TTJ 289 (Ahd)], Four Soft Pvt Ltd Vs DCIT [ (2014)149 ITD 732 (Hyd)], Prithvi Information Solutions Pvt Ltd Vs ACIT [(2014) 34 ITR (Tri) 429 (Hyd)] , which refer to the concept of „quasi capital‟ but none of these decisions throws any light on what constitutes „quasi capital‟ in the context of transfer…

DCIT CC 44, Mumbai vs. Sopariwala Exports, Mumbai

ITA 3039/MUM/2014[2007-08]Status: DisposedITAT Mumbai21 Sept 2021AY 2007-08
Section 132Section 143(2)Section 143(3)Section 153ASection 92

…quasi equity. He submitted that the delay in the formalities as noted by learned CIT(A) in allowing the appeal is not sustainable. Learned Departmental Representative referred to the decision of ITAT Delhi bench in the case of Perot Systems TSI (India) Ltd. (37 SOT 358) and submitted that the decision of Micro Inks Ltd. Vs. ACIT (144 ITD 610) relied upon by learned CIT(A) is not applicable. That the Assessing Officer applied Libor plus 4% amounting to 10% for making TP adjustment. Learned Departmental Representative left to us the decision to apply appropriate rate for making TP adjustment. 20 M/s. Sopariwala E…

Cadila Healthcare Ltd., Ahmedabad vs. The Deputy Commissioner of Income Tax, Circle-1(1)(2), Ahmedabad

In the result, the appeal for the assessment year 2013-14 is also partly allowed in the terms indicated above

ITA 213/AHD/2018[2013-14]Status: DisposedITAT Ahmedabad17 Aug 2021AY 2013-14
Section 143(3)

…reasoning, without an independent analysis of the provisions of the Act and the rules" the same seems to be the position with regard to "quasi capitals" There are several decisions of this Tribunal, including in the cases of Perot Systems TSI v. DCIT [(2010) 130 TTJ 685 (Del)]., Micro Inks Ltd. v. ACIT [(2013) 157 TTJ 289 (Ahd)], Four Soft Pvt. Ltd. v. DCIT [(2014) 149 ITD 732 (Hyd.)], Prithvi Information Solutions Pvt. Ltd. v. ACIT [(2014) 34 ITR (Tri) 429 Hyd.] , which refer to the concept of 'quasi capital' but none of these decisions throws any light on what constitutes 'quasi capital' in the context of tran…

Cadila Healthcare Ltd., Ahmedabad vs. The Deputy Commissioner of Income Tax, Circle-1(1)(2), Ahmedabad

In the result, the appeal for the assessment year 2013-14 is also partly allowed in the terms indicated above

ITA 954/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad17 Aug 2021AY 2012-13
Section 143(3)

…reasoning, without an independent analysis of the provisions of the Act and the rules" the same seems to be the position with regard to "quasi capitals" There are several decisions of this Tribunal, including in the cases of Perot Systems TSI v. DCIT [(2010) 130 TTJ 685 (Del)]., Micro Inks Ltd. v. ACIT [(2013) 157 TTJ 289 (Ahd)], Four Soft Pvt. Ltd. v. DCIT [(2014) 149 ITD 732 (Hyd.)], Prithvi Information Solutions Pvt. Ltd. v. ACIT [(2014) 34 ITR (Tri) 429 Hyd.] , which refer to the concept of 'quasi capital' but none of these decisions throws any light on what constitutes 'quasi capital' in the context of tran…

Bilakhia Holding P Ltd, Vapi vs. The ACIT, Vapi Circle, Vapi

In the result, the appeal of the assessee is allowed for assessment year 2010-11

ITA 182/SRT/2017[2010-11]Status: DisposedITAT Surat19 May 2021AY 2010-11

Bench: Shri Pawan Singh, Hon'Ble & Dr.Shri Arjun Lal Saini, Hon'Ble(Virtual Hearing) आ.अ.सं./I.T.A’S No.181 & 182/Srt/2017 "नधा"रण वष"/Assessment Years: 2009-10 & 2010-11 Bilakhia Holding P Ltd., Vs The Assistant Bilakhia House, Muktanand Marg, . Commissioner Of Income Chala, Surat – 394 520. Tax, Vapi Circle, Vapi. [Pan: Aadcs 4420 J] अपीलाथ" / Appellant ""यथ"/Respondent "नधा"रतीक"ओर से /Assessee By Shri Gopalakrishnan Aiyer – Ar राज"वक"ओर से /Revenue By Smt. Usha Shrote – Sr.Dr सुनवाई की तारीख/ Date Of Hearing: 13.04.2021 उ"घोषणा क" तार"ख/Pronouncement On: 19.05.2021 आदेश /O R D E R Per Dr.Arjun Lal Saini, Accountant Memeber: 1. Captioned Two Appeals Filed By Assessee Pertaining To Assessment Year 2009-10 & 2010-11, Are Directed Against The Separate Orders Passed By The Ld.Cit(A), Which In Turn Arise Out Of Separate Orders Passed By The Assessing Officer Under Section 271(1)(C) Of The Income Tax Act, 1961 (Here In After Referred To As The ‘Act’).

Section 143(3)Section 271Section 271(1)Section 271(1)(C)Section 271(1)(c)Section 274Section 92C

…actions as shareholder’s activity and after detailed analysis justified the ALP for interest at Nil. The TPO/CIT(A) has rejected the aforesaid T P Study report and arbitrarily adopted the CUP method. The finding in the case of Perot Systems TSI v. DCIT [2010] 37 SOT 358 (Delhi-Trib) that profits are shifted out of India to Bermuda, a Tax Heaven. However, in the instant case, the AE subsidiary has been formed with the intention and the structure of the transaction is to bring back the capital and profits to India after payment of due taxes. Therefore, the decision in the case of Perot System TSI (India) Limited vs…

Bilakhia Holding P Ltd, Vapi vs. The ACIT, Vapi Circle, Vapi

In the result, the appeal of the assessee is allowed for assessment year 2010-11

ITA 181/SRT/2017[2009-10]Status: DisposedITAT Surat19 May 2021AY 2009-10

Bench: Shri Pawan Singh, Hon'Ble & Dr.Shri Arjun Lal Saini, Hon'Ble(Virtual Hearing) आ.अ.सं./I.T.A’S No.181 & 182/Srt/2017 "नधा"रण वष"/Assessment Years: 2009-10 & 2010-11 Bilakhia Holding P Ltd., Vs The Assistant Bilakhia House, Muktanand Marg, . Commissioner Of Income Chala, Surat – 394 520. Tax, Vapi Circle, Vapi. [Pan: Aadcs 4420 J] अपीलाथ" / Appellant ""यथ"/Respondent "नधा"रतीक"ओर से /Assessee By Shri Gopalakrishnan Aiyer – Ar राज"वक"ओर से /Revenue By Smt. Usha Shrote – Sr.Dr सुनवाई की तारीख/ Date Of Hearing: 13.04.2021 उ"घोषणा क" तार"ख/Pronouncement On: 19.05.2021 आदेश /O R D E R Per Dr.Arjun Lal Saini, Accountant Memeber: 1. Captioned Two Appeals Filed By Assessee Pertaining To Assessment Year 2009-10 & 2010-11, Are Directed Against The Separate Orders Passed By The Ld.Cit(A), Which In Turn Arise Out Of Separate Orders Passed By The Assessing Officer Under Section 271(1)(C) Of The Income Tax Act, 1961 (Here In After Referred To As The ‘Act’).

Section 143(3)Section 271Section 271(1)Section 271(1)(C)Section 271(1)(c)Section 274Section 92C

…actions as shareholder’s activity and after detailed analysis justified the ALP for interest at Nil. The TPO/CIT(A) has rejected the aforesaid T P Study report and arbitrarily adopted the CUP method. The finding in the case of Perot Systems TSI v. DCIT [2010] 37 SOT 358 (Delhi-Trib) that profits are shifted out of India to Bermuda, a Tax Heaven. However, in the instant case, the AE subsidiary has been formed with the intention and the structure of the transaction is to bring back the capital and profits to India after payment of due taxes. Therefore, the decision in the case of Perot System TSI (India) Limited vs…

M/S. Dabur India Ltd., New Delhi vs. Addl.CIT, New Delhi

In the result, the appeals filed by the Revenue are partly allowed and the appeals filed by the assessee are partly allowed for statistical purposes

ITA 6525/DEL/2014[2008-09]Status: DisposedITAT Delhi18 Feb 2021AY 2008-09

Bench: Shri R.K. Panda & Ms Suchitra Kamble

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri Anupam Kant Garg, CIT-DR
Section 115JSection 143(1)Section 143(2)Section 143(3)Section 80GSection 80ISection 92CSection 92E

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH : I-2 : NEW DELHI BEFORE SHRI R.K. PANDA, ACCOUNTANT MEMBER AND MS SUCHITRA KAMBLE, JUDICIAL MEMBER ITA Nos.3241 & 6525/Del/2014 Assessment Years: 2007-08 & 2008-09 Dabur India Ltd., Vs Addl. CIT, Punjabi Bhawan, 4th Floor, Range-10, 10, Rouse Avenue, New Delhi. New Delhi. PAN : AAACD0474C ITA Nos.3114 & 6256/Del/2014 Assessment Years: 2007-08 & 2008-09 Addl. CIT, Vs. Dabur India Ltd., Punjabi Bhawan, 4th Floor, Range-10, New Delhi. 10, Rouse Avenue, New Delhi. PAN : AAACD0474C (Appellant) (Respondent) Assessee by : Shri Ajay Vohra, Sr. Advocate, Shri Rohit Jain,…

DCIT, New Delhi vs. M/S. Dabur India Ltd., New Delhi

In the result, the appeals filed by the Revenue are partly allowed and the appeals filed by the assessee are partly allowed for statistical purposes

ITA 6256/DEL/2014[2008-09]Status: DisposedITAT Delhi18 Feb 2021AY 2008-09

Bench: Shri R.K. Panda & Ms Suchitra Kamble

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri Anupam Kant Garg, CIT-DR
Section 115JSection 143(1)Section 143(2)Section 143(3)Section 80GSection 80ISection 92CSection 92E

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH : I-2 : NEW DELHI BEFORE SHRI R.K. PANDA, ACCOUNTANT MEMBER AND MS SUCHITRA KAMBLE, JUDICIAL MEMBER ITA Nos.3241 & 6525/Del/2014 Assessment Years: 2007-08 & 2008-09 Dabur India Ltd., Vs Addl. CIT, Punjabi Bhawan, 4th Floor, Range-10, 10, Rouse Avenue, New Delhi. New Delhi. PAN : AAACD0474C ITA Nos.3114 & 6256/Del/2014 Assessment Years: 2007-08 & 2008-09 Addl. CIT, Vs. Dabur India Ltd., Punjabi Bhawan, 4th Floor, Range-10, New Delhi. 10, Rouse Avenue, New Delhi. PAN : AAACD0474C (Appellant) (Respondent) Assessee by : Shri Ajay Vohra, Sr. Advocate, Shri Rohit Jain,…