How many judgments cite Sony India (P) Ltd. v. DCIT?

131 judgments on BharatTax cite Sony India (P) Ltd. v. DCIT (114 ITD 448), spanning 2015 to 2025.

Which sections of the Income Tax Act does Sony India (P) Ltd. v. DCIT come up under?

It is most often cited in judgments turning on Section 143(3), Section 133(6), Section 147, Section 148, Section 14A, Section 151.

Sony India (P) Ltd. v. DCIT

114 ITD 448Income Tax Appellate Tribunal2008#783 most cited

What is Sony India (P) Ltd. v. DCIT authority for?

For transfer pricing purposes, functionally dissimilar entities that have significant business differences must be excluded from the list of comparables for benchmarking analysis. It also provides guidance on the non-allocation of advertisement, marketing, and promotion (AMP) expenses to other entities when incurred solely for the assessee's business.

131

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2015 to 2025.

Also referred to as

Sony India (P) Ltd. v. DCIT · 114 ITD 448 · transfer pricing · comparables exclusion · functional dissimilarity · benchmarking analysis · AMP expenses · allocation of AMP expenditure · section 92BA · working capital adjustment · section 37(1) · associated enterprises

Also reported as

118 TTJ 865

Sections most often in play

Section 143(3)Section 133(6)Section 147 Section 148 Section 14A Section 151 Section 37(1)Section 80IC

Issues it is cited on

amp expenditure section 92ba true and full disclosure captive service provider sanction under section 151 transfer pricing order working capital adjustment fresh tangible material section 148(2)sanctioning authority specified domestic transaction tested party

Judgments citing Sony India (P) Ltd. v. DCIT

Hewitt Associates (India) Pvt. Ltd., Gurgaon vs. ACIT, New Delhi

In the result, the appeal of the assesee is treated as allowed for statistical purposes

ITA 5736/DEL/2011[2007-08]Status: DisposedITAT Delhi31 May 2022AY 2007-08

Bench: Shri R.K. Panda & Ms. Astha Chandraasstt. Year : 2007-08

For Appellant: Shri Atul Jain &For Respondent: Shri Surender Pal, CIT-DR

…INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “I-1”: NEW DELHI BEFORE SHRI R.K. PANDA, ACCOUNTANT MEMBER AND MS. ASTHA CHANDRA, JUDICIAL MEMBER Asstt. Year : 2007-08 Hewitt Associates (India) Vs. ACIT Private Limited, Circle-12(1) Hewitt Tower, Sector-42, New Delhi. DLF City, Gurgaon, Haryana PAN AABCH1559D (Appellant) (Respondent) Assessee by: Shri Atul Jain & Shri Arpan Khanna, CA Department by : Shri Surender Pal, CIT-DR Date of Hearing 08.03.2022 Date of 31.05.2022 pronouncement O R D E R PER ASTHA CHANDRA, JM The appeal of the assessee is preferred against the order of Ld. Asstt. Commissioner of Income Ta…

Addl.CIT, Special Range-3, New Delhi vs. Escorts Ltd., Faridabad

In the result, the Revenue’s appeal is partly allowed for statistical purposes

ITA 5558/DEL/2018[2012-13]Status: DisposedITAT Delhi05 May 2022AY 2012-13

Bench: Shri R.K. Panda & Ms. Astha Chandraasstt. Year : 2008-09

For Appellant: Shri R.M. Mehta, AdvocateFor Respondent: Shri Mrinal Kumar Das, Sr. DR

Section 143(3)Section 144C

…ujrat Tractor Ltd. 6.1 The Ld. TPO has rejected this company on the ground of having negative net worth relying upon the decision of the Hon’ble ITAT in the case of DCIT vs. Quark Systems Pvt. Ltd. [2010-TIOL-31-ITAT-CHD-SB] and Sony India (P) Ltd. vs. DCIT [114 ITD 448 (Del)]. 6.2 The Ld. CIT(A) endorsed the Ld. TPO’s finding by holding that the negative worth company will have excess liability which affects the profitability. 6.3 Before us, the Ld. AR reiterated the submissions made before the Ld. TPO/ CIT(A) and argued that this company should not be excluded as a comparable merely on the ground that it has…

Escorts Ltd., New Delhi vs. DCIT, Circle- 11(1), New Delhi

In the result, the Revenue’s appeal is partly allowed for statistical purposes

ITA 3889/DEL/2017[2008-09]Status: DisposedITAT Delhi05 May 2022AY 2008-09

Bench: Shri R.K. Panda & Ms. Astha Chandraasstt. Year : 2008-09

For Appellant: Shri R.M. Mehta, AdvocateFor Respondent: Shri Mrinal Kumar Das, Sr. DR

Section 143(3)Section 144C

Asst CIT (Ltu) 2, Mumbai vs. Asian Paints Ltd, Mumbai

In the result, appeal filed by the assessee is partly allowed as directed above

ITA 4675/MUM/2015[2010-11]Status: DisposedITAT Mumbai23 Feb 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Asst. Commissioner Income Asian Paints Ltd. Tax, (Large Taxpayer Unit)-2, 6A Shanti Nagar, Cuffe Parade,, 29 Th Floor, Santacruz (East), World Trade Centre, Cuffee Mumbai-400 055 Vs. Parade, Mumbai-400 005 (Respondent) (Appellant) Pan No. Aaaca3622K Asian Paints Ltd. Vs. Addl. Commissioner Of 6A Shanti Nagar, Income Tax-Ltu Cuffe Parade,, 29 Th Floor, Santacruz (East), Mumbai-400 055 World Trade Centre, Cuffee Parade, Mumbai-400 005 (Appellant) (Respondent) Appellant By : Shri Milind Chavan, Sr Dr Respondent By : Shri Madhur Agrawal, Advocate Date Of Hearing: 09.12.2021 Date Of Pronouncement : 23.02 .2022 O R D E R Per Prashant Maharishi, Am: 01. These Are Cross Appeals Filed By Asian Paints Ltd [Appellant/Assessee] & The Additional Commissioner Of Income Tax – Large Taxpayers Unit

For Appellant: Shri Milind Chavan, Sr DRFor Respondent: Shri

Section 14ASection 35

…otal sales which is much less. Reliance was placed by him on the following decisions:- 1. CIT v/s Global Healthline P. Ltd., [2012] 19 ITR 298 (Del.) (Trib.) 2. ITO v/s Spice Communication Ltd., [2010] 35 SOT 78 (Del.) 3. Sony India P. Ltd. V/s DCIT [2008] 114 ITD 448 (Del.) 4. CIT v/s Citi Financial Consumer Finance Ltd., [2011-TOIL-309-HC-Del-IT) ITA No.4675 & 3290/Mum/2015 Asian Paints Ltd; AY 10-11 5. CIT v/s Adidas India Marketing P. Ltd., [2010] 105 Taxman 256 (Del.) 6. DCIT v/s Warner Lambert (I) Pvt. Ltd. [2012] 143 TTJ 571 (Mum.)(Trib.) He further submitted that the learned Commissioner (Appeals) h…

First Advantage Global Operating Center Private Limited, Bangalore vs. DCIT, Bangalore

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

ITA 370/BANG/2015[2010-11]Status: DisposedITAT Bangalore02 Nov 2021AY 2010-11

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2010-11

For Appellant: Shri Vikram Vijayaraghavan, AdvocateFor Respondent: Shri Muzaffar Hussain, CIT(DR)(ITAT), Bengaluru

Section 10ASection 143(3)Section 253

…. ITO, IT(TP)A No.113/Bang/2018 AY 2012-13, Bangalore Tribunal by order dated 05.12.2019 has held as under:- “We have considered the submission of the learned AR on this issue and find that in the decision rendered in the case of Sony India (P) Ltd. Vs. DCIT 114 ITD 448 (Delhi), this aspect has been considered and it was held that provisions written back in the P&L a/c should be regarded as forming part of the operating profit of the taxpayer. The relevant observations of the Tribunal are as follows:- “106.2 After considering facts and circumstances of the case, we do not see any good ground for not permitting t…

Joint Commissioner of Income Tax Ltu (OSD) Circle-1, Bangalore vs. M/S Toyota Kirloskar Motors Pvt Ltd, Bangalore

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

ITA 2016/BANG/2018[2013-14]Status: DisposedITAT Bangalore18 Aug 2021AY 2013-14

Bench: Shri George George K, Jm & Shri B.R.Baskaran, Am

For Appellant: Sri.P.C.Kincha, CAFor Respondent: Sri.Muzaffar Hussaain, CIT-DR

Section 192

…r of creation these provisions are treated as operating in nature, the reversal of the same is also to be treated as operating in nature. The CIT(A) by placing reliance on the order of the Delhi Bench of the Tribunal in the case of Sony India (P) Ltd. v. DCIT 114 ITD 448 (Delhi) and the order of the Bangalore Bench of the Tribunal in the case of Logica Private Limited v. ACIT 36 taxmann.com 374 (Blr.) held that the provisions written back should be treated as operating in nature. 8.2 The Revenue being aggrieved has raised this issue before the Tribunal. 22 ITA No.2016 & 1972/Bang/2018. M/s.Toyota Kirloskar Moto…

M/S. Toyota Kirloskar Motor Private Limited, Bangalore vs. The Assistant Commissioner of Income Tax, Circle-1, Ltu, Bangalore

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

ITA 1972/BANG/2018[2013-14]Status: DisposedITAT Bangalore18 Aug 2021AY 2013-14

Bench: Shri George George K, Jm & Shri B.R.Baskaran, Am

For Appellant: Sri.P.C.Kincha, CAFor Respondent: Sri.Muzaffar Hussaain, CIT-DR

Section 192

Goodyear India Ltd., Faridabad vs. Neac, Delhi

In the result, the appeal of the assessee is allowed

ITA 467/DEL/2021[2016-17]Status: DisposedITAT Delhi11 Aug 2021AY 2016-17

Bench: Shri Kul Bharat & Dr.B.R.R.Kumarassessment Year : 2016-17 Goodyear India Ltd., Vs Neac, Mathura Road, Ballabhgarh, Delhi. Faridabad, Haryana-121001. Pan-Aaacg3511H Appellant Respondent Appellant By Sh. Neeraj Jain, Adv. & Sh. Abhishek Agarwal, Adv. Respondent By Sh. Surendra Pal, Cit Dr Date Of Hearing 08.07.2021 Date Of Pronouncement 11.08.2021

Section 143(3)Section 144CSection 234B

…hatta Family Trust (215 Taxman 602) (Guj). (xi) Star India P. Ltd.: 103 ITD 73 (TM) (xii) National Panasonic (India) Ltd. vs. JCIT: ITA 3238/Del/2002 (Del) (xiii) Nestle India Ltd. vs. DCIT (Del)(2007) 111 ITR 498 (Del). (xiv) Sony India P. Ltd. vs. DCIT: 114 ITD 448. (xv) CIT vs Adidas India Marketing (P) Ltd 195 Taxman 256 (Del). (xvi) CIT vs Agra Beverages Corporation P Ltd (ITA No. 966/2009 & 836/2010)(Del) (xvii) DCIT vs. Maruti Countrywide Auto Financial Services P. Ltd. (ITA Nos. 2181 to 2183/De1/2010). (xviii) CIT vs Modi Revlon P.Ltd. (ITA No.1450, 1451, 1640, 1652/2010 & 825/201) (2012). (xix) AC…

Sun Pharmaceuticals Industries Ltd. ( Erstwhile Ranbaxy Laboratories Limited), Baroda vs. The ACIT, Cent.Circle-1, Baroda

ITA 702/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad08 Apr 2021AY 2011-12

For Appellant: Shri S.N. Soparkar, Sr. A.RFor Respondent: Shri Mohd Usman, CIT-D.R

Section 115JSection 143(2)Section 143(3)Section 144CSection 144C(5)Section 37(1)Section 92C

…s." We are in agreement with the findings of the earlier Bench (supra) that such a selected party should be least complex and should not be unique. (ii) Development Consultants (P.) Ltd. v. ACIT 136 TTJ 129 & followed by Sony India (P.) Ltd. v. Dy. CIT [2008] 114 ITD 448/315 ITR 150 (Delhi): The issue before the Tribunal was that the CIT (A) had confirmed the adjustments to the international transactions of the assessee with its AEs based at Bahamas, USA without considering the submissions and the financial of the AEs explaining the facts etc. In case of the merits of the case for international transactions enter…

Roxtec India Private Limited, New Delhi vs. ACIT, Circle- 21(2), New Delhi

In the result, the appeal of the assessee is allowed in part and for statistical purposes

ITA 3840/DEL/2017[2013-14]Status: DisposedITAT Delhi22 Feb 2021AY 2013-14

Bench: Shri Anil Chaturvedi & Shri K. Narasimha Charyassessment Year: 2013-14

For Appellant: Mr. Vijay Mehta, CAFor Respondent: Sh. Sunil Kumar, CIT/DR

Section 144CSection 154

…s Ltd., Infosys BPO and Wipro Ltd., which were having huge turnover about 23 times and 65 times etc. and rejected them to be good comparables because of the huge turnover gap. The Tribunal also placed reliance on the decisions in Sony India (P) Ltd. vs. DCIT, 114 ITD 448, E-gain Communication, 2008 TIOL 282, Deloittee Consulting India Pvt. Ltd. vs. DCIT(ITA No. 1082/Hyd/2010 and Genisys Integrating System (India) (P) Ltd. vs. DCIT, 53 SOT 159. The Hon’ble Highcourt approved the rejection of the entities operating at large scale and whose turnover is more than 23 to 65 times to the comparables. That being so, the…

Marathon Electric India Pvt. Ltd., Faridabad vs. ACIT, Faridabad

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

ITA 6100/DEL/2012[2008-09]Status: DisposedITAT Delhi27 Nov 2020AY 2008-09

Bench: Shri R. K. Panda & Ms Suchitra Kamble(Through Video Conferencing) Marathon Electric India Pvt. Vs Acit Ltd. Circle-1 Sector-11, Faridabad Model Town Faridabad (Respondent) Aaacg5525H (Appellant)

Section 10BSection 144Section 254Section 92D

…ndia Ltd. And Actis Advisors Pvt. Ltd. Vs. DCIT {2012-TII-136- ITAT-DEL-TP} Stream International Services Pvt. Ltd. Vs. ACIT {2013- TII-42-ITAT-MUM-TP} As regards to diminishing Revenues Trend, the Ld. DR relied upon the case of Sony India Pvt. Ltd. Vs DCIT (114 ITD 448) where one of the Consequences of such erroneous trend in growth of company is also the company resulting into negative net worth. As regards to persistent loss and peculiar circumstances filter and negative net worth, the Ld. DR relied upon the following decisions:- a. CRM SERVICES INDIA (P) LTD (2011-TII-86-ITAT-DEL-TP) b. EXXON MOBIL COMPANY…

M/S. Denso India Pvt. Ltd., New Delhi vs. DCIT, New Delhi

The appeal of the assessee is partly allowed for statistical purpose

ITA 1078/DEL/2016[2011-12]Status: DisposedITAT Delhi23 Nov 2020AY 2011-12

Bench: Shri R. K. Panda & Ms Suchitra Kamble(Through Video Conferencing) Denso India Pvt. Ltd. Vs Dcit B-1/D4, Ground Floor, Circle-7(1) Mohan Cooperative Industrial New Delhi Estate, Mathura Road New Delhi (Respondent) Aaacd4255F (Appellant) Appellant By Sh. Ravi Sharma, Adv & Sh. Anubhav Rastogi, Adv Respondent By Sh. Surendar Pal, Cit Dr Date Of Hearing 01.09.2020 Date Of Pronouncement 23.11.2020

Section 144Section 254Section 92CSection 92D

…ORLDWIDE SOLUTIONS PVT LTD Vs ACIT (2015-TII-430-ITAT-BANG-TP) 14 and Birla soft for A.Y. 2009-10. In respect of diminishing Revenues Trend, the Ld. DR submitted that the Tribunal has upheld application of this filter in case of Sony India Pvt. Ltd. Vs DCIT (114 ITD 448). One of the Consequences of such erroneous trend in growth of company is also the company resulting into negative net worth. As regards to persistent loss and peculiar circumstances filter and negative net worth, the Ld. DR relied upon the following decisions: a. SONY INDIA (P) LIMITED VS DCIT (114 ITD 448) b. CRM SERVICES INDIA (P) LTD (2011-T…

Stmicroelectronics Pvt. Ltd., New Delhi vs. DCIT, New Delhi

ITA 6169/DEL/2012[2008-09]Status: DisposedITAT Delhi28 Sept 2020AY 2008-09

Bench: Shri N.K. Billaiya & Shri Kuldip Singh

For Appellant: Shri Ajay Vohra, Senior AdvocateFor Respondent: Shri Anupam Kant Garg, CIT DR

Section 143Section 143(3)Section 144C

…ble and accurate adjustment to eliminate the differences having material effect.’ If these differences are not eliminated or removed, the comparison becomes unsound and unreliable. Further also, the decision of the Delhi Bench in the case of Sony India P Ltd (114 ITD 448) was cited for the proposition that deduction of 20% is allowable for various differences on account of intangibles, R&D, risk factors, working capital, etc. Referring to contents of the para 132 and 137 of the said decision, Sri Lohia stated that in that case the CIT(A) allowed adjustment to the extent of 10% against the 20% allowed by the TPO.…

Smart Cube India Pvt. Ltd., Noida vs. ACIT, New Delhi

In the result, appeal of the assessee is partly allowed

ITA 6078/DEL/2015[2011-12]Status: DisposedITAT Delhi29 Jul 2020AY 2011-12

Bench: Sh. Anil Chaturvedi & Sh. Sudhanshu Srivastava(Through Video Conferencing) Assessment Year: 2011-12 Smart Cube India Pvt. Ltd. Vs. Acit, Tower-B, Windsor It Park, Circle – 24(1), A-1, Sector-125 New Delhi Noida – 201 301 Pan No. Aahcs 8978 H (Appellant) (Respondent) Appellant By Shri Ajay Vohra, Sr. Advocate Shri Neeraj Jain, Advocate Shri Ramit Katiyal, Advocate Shri M. Baranwal, Sr. D.R. Respondent By Date Of Hearing: 16/07/2020 Date Of Pronouncement: 29/07/2020 Order Per Anil Chaturvedi, Am: This Appeal Filed By The Assessee Is Directed Against The Order Of The Assistant Commissioner Of Income Tax (Acit), Circle 24(1), New Delhi Pursuant To The Directions Of Drp, Passed U/S 143(3) R.W.S 144C Of The Income-Tax Act Dated 22.01.2015 Relating To Assessment Year 2011-12. Smart Cube India Pvt. Ltd Vs. Acit A.Y. 2011-12 2 2. The Relevant Facts As Culled From The Material On Records Are As Under:

Section 115JSection 143(2)Section 143(3)Section 144CSection 144C(5)Section 92C

…of liabilities are related to the core operation of the assessee and therefore, should have been taken into consideration while computing the margin of the assessee and in support of which he placed reliance on the decision in the case of Sony India Pvt. Ltd. 114 ITD 448 (Del) and Suessen Asia Pvt. Ltd. in ITA No. 1629/PUN/2011, the copies of which are placed in the paper book. 18. He submitted that if the aforesaid incomes are considered to be part of an operating income, the operating margin of the assessee would workout to 7.64%, and will be within the +/- 5% range of the margin of comparables and therefore,…

Softdel Systems P.Ltd, Mumbai vs. DCIT Cir 3(3), Mumbai

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

ITA 2969/MUM/2015[2009-10]Status: DisposedITAT Mumbai12 Mar 2020AY 2009-10

Bench: Us, Are As Follows:

Section 143(3)

…the earlier Bench (supra) that such a selected party should be least complex and should not be unique. ITA No. 2969/Mum/15 Assessment year: 2009-10 Page 4 of 10 (ii) Development Consultants (P) Ltd. (supra) followed by Sony Indis (P.) Ltd. v. Dy. CIT [2008] 114 ITD 448 (Delhi) The issue before the Tribunal was that the CIT (A) had confirmed the adjustments to the international transactions of the assessee with its AEs based at Bahamas, USA without considering the submissions and the financial of the AEs explaining the facts etc. In case of the merits of the case for international transactions entered by the ass…

Hyundai Rotem Company, Delhi vs. ACIT (International Taxation), New Delhi

In the result, the appeal of the assessee is allowed

ITA 7569/DEL/2019[2015-16]Status: DisposedITAT Delhi02 Mar 2020AY 2015-16

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Appellant: Shri Rajan Vohra, ARFor Respondent: Shri Sanjay I- Bara, CIT-D.R

Section 143(3)Section 144C(5)Section 234BSection 234C

…e quantification of the risk adjustment which has been placed in the paper book at pages 447 to 449, wherein it has given the difference between the bank rates and SBI base rates and quantification factor as been laid down by the Sony India (P) Ltd. vs. DCIT, 114 ITD 448. 29. Accordingly, we direct the TPO to examine the assessee’s quantification of risk adjustment specifically where assessee has taken the difference between bank rates and SBI bank rate and the quantification done by the assessee of the risk adjustment on 10.50%, is correct or not. With this direction this issue is remanded back to the TPO/Assess…

Tyco Valves & Controls (India) Pvt. Ltd., Baroda vs. The Dy.CIT, Baroda Cir- 4, Baroda

In the result, Assessee’s appeal is partly allowed for statistical purpose

ITA 2993/AHD/2011[2007-08-]Status: DisposedITAT Ahmedabad22 Jan 2020

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

For Appellant: Shri S.N. Soparkar, Sr.AdvFor Respondent: Shri Mahesh Shah, CIT-DR

Section 10BSection 144C(5)Section 920(2)

…175 (Bangalore-Trib.) 2. DBOI Global Services (P.) Lt. (2016) 74 taxmann.com 83 (Mumbai – Trib.) 3. Yodlee Infotech (P.) Ltd. (2016) 75 taxmann.com 258 (Bangalore – Trib.) 4. Sony India Pvt.Ltd. (ITA Nos.1189/Del/2005, 819/Del/2007 & 820/Del/2007) and (2008) 114 ITD 448 (DELHI) 5. Global Logic India Pvt.Ltd. (023) 31 taxmann.com 81 (Delhi – Trib.) ii. The comparable company is following financial year beginning from July to June whereas the assessee being the tested party is following the financial year from April to March. Therefore the same should be rejected as a comparable. The learned AR in support of his…

M/S. Amd India Private Ltd, Bangalore vs. Income-Tax Officer, Bangalore

In the result, the appeal is partly allowed

ITA 113/BANG/2017[2011-12]Status: DisposedITAT Bangalore05 Dec 2019AY 2011-12

Bench: Shri N.V. Vasudevan & Shri D.S. Sunder Singhit(Tp)A No.113/Bang/2018 Assessment Year: 2012-13

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri Pradeep Kumar, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 92Section 92C

…the TPO. 14. The assessee submits that as the reversal of provision is linked to business activity, the same should be treated as operating in nature. In support of this, the assessee relies on the following decisions: i) Sony India (P.) Ltd. V. DCIT [2008] 114 ITD 448 (Delhi) ii) Logica Private Limited v. ACIT [2013] 36 taxmann.com 374 (Bangalore-Trib). 15. We have considered the submission of the learned AR on this issue and find that in the decision rendered in the case of Sony India (P) Ltd. Vs. DCIT 114 ITD 448 (Delhi), this aspect has been considered and it was held that provisions written back in the P&…

Samsung India Electronics Pvt. Ltd., Gurgaon vs. Addl. CIT, New Delhi

ITA 1567/DEL/2014[2009-10]Status: DisposedITAT Delhi04 Oct 2019AY 2009-10

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Appellant: S/Shri Himanshu Sinha, ShriFor Respondent: Shri H.K. Choudhary, CIT-D.R

…of glass shells, funnels and panels which are used in manufacturing of colour TV. Videocon enjoys cost benefits due to captive manufacturing of CTV shells. The Ld. Counsel relied on the decision of this Tribunal in the case of Sony India P. LTD V DCIT [2008] 114 ITD 448 (Del) in this regard where on similar facts Videocon was held to be incomparable to Sony India, a company that was engaged in the manufacture of TVs and other consumer goods, on the ground that it undertakes manufacturing of components for CTV units which renders it functionally incomparable to companies which import the same parts. 61. We have…

Samsung India Electronics Pvt. Ltd., Gurgaon vs. Addl. CIT, New Delhi

ITA 52/DEL/2013[2008-09]Status: DisposedITAT Delhi04 Oct 2019AY 2008-09

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Appellant: S/Shri Himanshu Sinha, ShriFor Respondent: Shri H.K. Choudhary, CIT-D.R