WOODWARD INDIA PVT. LTD.,GURGAON vs. DCIT, NEW DELHI
The appeal of the assessee stands partly allowed
ITA 916/DEL/2015[2009-10]Status: DisposedITAT Delhi25 Mar 2019AY 2009-10
Bench: Shri N.K. Billaiya & Shri Sudhanshu Srivastavaassessment Year: 2009-10 Woodward India Pvt. Ltd., Dcit, (Formerly Known As Woodward Circle-18(1), Governor India Ltd.,), 12Th Floor, New Delhi. Vs Building No. 5, Dlf Cyber Terraces, Dlf Cyber City, Phase-Iii, Gurgaon-122002 Appellant Respondent Assessee By : Shri Vishal Kalra, Adv. Shri S.S. Tomer, Adv. Department By: Shri H.K. Choudary, C.I.T. Dr Date Of Hearing: 17.01.2019 Date Of Pronouncement: 25.03.2019
For Appellant: Shri Vishal Kalra, AdvFor Respondent: Shri H.K. Choudary, C.I.T. DR
Section 92Section 92C
…elhi High Court vide order dated March 3, 2017 (ITA 123/2017). SLP filed by the Revenue authorities has been dismissed by the Hon’ble Supreme Court vide order dated January 19, 2018 (SLP (civil) No. 41702/2017); • Cummins India Limited vs. Addl. CIT [2015] 68 SOT 14 (Pune Tribunal.); 3.18 Further reliance was also placed on the following decisions wherein it has been held that the TPO is to conduct a transfer pricing analysis and determine ALP in accordance with law and that the TPO cannot determine whether there is a service from which the assessee benefits or not and, therefore, the TPO cannot determine…
