“reference to TPO”

Jubilant Pharmova Limited, Uttar Pradesh vs. DCIT/ACIT (Central), Moradabad

In the result, all two appeals of the assessee are allowed

Bench: Shrivikas Awasthy & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.1970/Del/2022 िनधा"रणवष"/Assessment Year: 2018-19 बनाम Jubilant Pharmova Ltd., Acit-1, Plot-1A, Sector-16A, District G.B. Vs. Moradabad-New, Nagar, Noida,Uttar Pradesh. Uttar Pradesh. Pan No.Aabcv0200H अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.5713/Del/2024 िनधा"रणवष"/Assessment Year: 2021-22 बनाम Jubilant Pharmova Ltd., Dcit/Acit (Central), Bhartiagram Gajraula, Vs. Income Tax Department, Plot-1A, Sector-16A,District G.B. Moradabad, Uttar Pradesh. Nagar, Noida,Uttar Pradesh. Pan No.Aabcv0200H अपीलाथ" Appellant ""यथ"/Respondent

passed within the extended period, as otherwise the extension becomes meaningless. (e) The outer time limit of 33 months in case of reference to TPO under Section 153, would not refer to draft order, but only to final order and hence, the entire proceedings would have to be concluded within

Jubilant Foodworks Limited, Noida vs. Assistant Commissioner of Income Tax, Noida

ITA NOS. 4339/D/2024 & 5712/D/2024 JUBILANT FOODWORKS LTD. IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “I”NEW DELHI BEFORE SHRI

Jinfei Trading India Pvt Ltd, Gurgaon vs. DCIT, Circle - 13(1), Delhi

Bench: Shri Vikas Awasthy & Shri Sanjay Awasthi

ITA Nos. 5517/D/24, 6114/D/24, 5522/D/24,5528/D/24, 6081/D/24 & 2348/D/22 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “I” NEW DELHI BEFORE

Fujitsu Consulting India Private Limited, Delhi vs. The Deputy Commissioner of Income-Tax, New Delhi

Bench: Shri Vikas Awasthy & Shri Sanjay Awasthi

ITA Nos. 5517/D/24, 6114/D/24, 5522/D/24,5528/D/24, 6081/D/24 & 2348/D/22 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH "I"NEW DELHI BEFORE

Airbnb Payments India Private Limited, Gurugram vs. The Deputy Commissioner of Income Tax, Circle 1(1), Gurugram, Haryana

Bench: Shri Vikas Awasthy & Shri Sanjay Awasthiआ.अ.सं/.I.T.A No.5517/Del/2024 िनधा"रणवष"/Assessment Year: 2021-22 बनाम Airbnb Payments India Private Limited, The Dcit Circle 1(1), Level 9, Spaze I Tech Park, A1 Tower,Sector Vs. Gurugram,Haryana. 49, Sohna Road, Gurugram, Haryana.India. Pan No. Aanca6203B अपीलाथ" Appellant ""यथ"/Respondent

passed within the extended period, as otherwise the extension becomes meaningless. (e) The outer time limit of 33 months in case of reference to TPO under Section 153, would not refer to draft order, but only to final order and hence, the entire proceedings would have to be concluded within

Pioneer India Electronics Private Limited, Gurgaon vs. DCIT, Circle 3(1), Gurgaon/ Assessment Unit/Income Tax Department, Gurgaon

In the result, appeals of the assessees are allowed

Bench: Shri Vikas Awasthy & Shri Sanjay Awasthiआअसं.5461/धिल्ली/2024(नि.व. 2021-22) Pioneer India Electronics P. Ltd., Unit No. 3, 10Th Floor Ambience Corporate, Tower-Ii, Nh-8 Plot No. 3 Ambience Island, Gurugram, Haryana 122002 ...... अपीलार्थी/Appellant Pan: Aaecp-8368-H बिाम Vs. Deputy Commissioner Of Income Tax, ..... प्रनिवादी/Respondent Circle 3(1), Gurgaon, Haryana 122001 आअसं.5951/धिल्ली/2024(नि.व. 2021-22) Mitsui & Co India P. Ltd., 4Th Floor, Worldmark 3, Asset 7, Aero City, Nh-8, New Delhi 110037 ...... अपीलार्थी/Appellant Pan: Aadcm-4488-J बिाम Vs. Deputy Commissioner Of Income Tax, ..... प्रनिवादी/Respondent Circle 16(1), Cr Building, Delhi 110002 आअसं.5999/धिल्ली/2024(नि.व. 2021-22) Rohde & Sehwarz India P. Ltd., A-27, First Floor, Mohan Corporate, Mathura Road, New Delhi 110044 ...... अपीलार्थी/Appellant Pan: Aaacr-3267-P बिाम Vs. Assessment Unit/Deputy Commissioner Of Income Tax, Circle 19(1), Cr Building, Ip Estate, New Delhi 110002 ..... प्रनिवादी/Respondent

passed within the extended period, as otherwise the extension becomes meaningless. (e) The outer time limit of 33 months in case of reference to TPO under Section 153, would not refer to draft order, but only to final order and hence, the entire proceedings would have to be concluded within

Fujitsu India Private Limited, Delhi vs. Assistant Commissioner of Income Tax, New Delhi

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahay

passed within the extended period, as otherwise the extension becomes meaningless. (e) The outer time limit of 33 months in case of reference to TPO under Section 153, would not refer to draft order, but only to final order and hence, the entire proceedings would have to be concluded within

L T Foods Limited, New Delhi vs. DCIT, Circle-13(1), New Delhi

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahayl T Foods Limited Vs Dcit Unit No. 134, Frist Floor, Circle 13(1) Rectdangle-1, Saket District Centre, New Delhi New Delhi Pan: Aaacl 0259K Appellant Respondent Assessee By Sh. Sh. Neeeraj Jain, Adv, Sh. Ramitkatiyar, Ar. Ms. Manshabhalla, Ca & Sh. Dhruv Seth, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 28/01/2026 Date Of Pronouncement 29/01/2026

passed within the extended period, as otherwise the extension becomes meaningless. (e) The outer time limit of 33 months in case of reference to TPO under Section 153, would not refer to draft order, but only to final order and hence, the entire proceedings would have to be concluded within

Renew Wind Energy (Rajkot) Private Limited, Delhi vs. Deputy Commissioner of Income-Tax, Circle 19(1), Delhi

In the result, appeals of the Assessees are allowed

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahayrenew Wind Energy (Shivpur) Vs The Deputy Commissioner Of Private Limited, 138, Ansal Income Tax, Circle 19(1) Delhi Chambers, Bhikaji Cama Palace, Range Code-44, C. R. New Delhi Building, I. P. Estate, Pan: Aafcr4810H New Delhi Appellant Respondent Renew Wind Energy (Rajkot) Vs The Deputy Commissioner Of Private Limited,138, Ansal Income Tax, Circle 19(1) Delhi Chambers, Bhikajicama Palace, Range Code-44, C. R. New Delhi Building, I. P. Estate, Pan: Aafcr4553H New Delhi Appellant Respondent Assessee By Sh. Kashish Gupta, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 27/01/2026 Date Of Pronouncement 29/01/2026

passed within the extended period, as otherwise the extension becomes meaningless. (e) The outer time limit of 33 months in case of reference to TPO under Section 153, would not refer to draft order, but only to final order and hence, the entire proceedings would have to be concluded within

Rohde and Schwarz India Private Limited, New Delhi vs. Assessment Unit, the Deputy Commissioner of Income Tax, Circle 19(1), New Delhi

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahayrohde & Schwarz India Private Vs Assessment Unit, The Limited Deputy Commissioner Of A-27, First Floor Mohan Cooperative Income Tax, Circle 19(1), Industrial Estate, Mathura Road, New Delhi New Delhi-110044 Pan: Aaacr3267P Appellant Respondent Assessee By Ms. Snigdha Gautam, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 27/01/2026 Date Of Pronouncement 29/01/2026

passed within the extended period, as otherwise the extension becomes meaningless. (e) The outer time limit of 33 months in case of reference to TPO under Section 153, would not refer to draft order, but only to final order and hence, the entire proceedings would have to be concluded within

Jubilant Foodworks Limited, Noida vs. Deputy Commissioner of Income Tax, Noida

In the result, all two appeals of the assessee are allowed

Bench: Shri Vikas Awasthy & Shri Sanjay Awasthiआ.अ.सं/.I.T.A No.4339/Del/2024 िनधा"रणवष"/Assessment Year: 2020-21 बनाम Jubilant Foodworks Limited, Deputy Commissioner Of Plot No.1A, Sector-16A, Noida,Gautam Vs. Income Tax, Buddha Nagar, Uttar Pradesh. Circle-5(1)(1), Noida, Pan No.Aabcd1821C Uttar Pradesh. अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.5712/Del/2024 िनधा"रणवष"/Assessment Year: 2021-22 बनाम Jubilant Foodworks Limited, Assistant Commissioner Of Plot No.1A, Sector-16A, Noida, Vs. Income Tax, Gautam Buddha Nagar, Uttar Pradesh. Circle 5(1)(1), Noida, Pan No.Aabcd1821C Uttar Pradesh. अपीलाथ" Appellant ""यथ"/Respondent

passed within the extended period, as otherwise the extension becomes meaningless. (e) The outer time limit of 33 months in case of reference to TPO under Section 153, would not refer to draft order, but only to final order and hence, the entire proceedings would have to be concluded within

Zimmer India Private Limited, Gurgaon, Haryana vs. The Deputy Commissioner of Income Tax, Gurgaon, Haryana

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahayzimmer India Private Limited V The Deputy Commissioner Vanijya Nikunj, Enkay Towers, Unit S Of Income Tax, Circle 3(1) No. 6Th Floor, Udyog Vihar, Phase-V, Hsiidc Building, Udyog Gurgaon, 122016, Haryana Vihar V, Gurugram Haryana Pan: Aaecs7432H Appellant Respondent Assessee By Sh. Kashish Gupta, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 27/01/2026 Date Of Pronouncement 29/01/2026

passed within the extended period, as otherwise the extension becomes meaningless. (e) The outer time limit of 33 months in case of reference to TPO under Section 153, would not refer to draft order, but only to final order and hence, the entire proceedings would have to be concluded within

Renew Wind Energy (Shivpur) Private Limited, Delhi vs. Deputy Commissioner of Income-Tax, Circle 19(1), Delhi

In the result, appeals of the Assessees are allowed

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahayrenew Wind Energy (Shivpur) Vs The Deputy Commissioner Of Private Limited, 138, Ansal Income Tax, Circle 19(1) Delhi Chambers, Bhikaji Cama Palace, Range Code-44, C. R. New Delhi Building, I. P. Estate, Pan: Aafcr4810H New Delhi Appellant Respondent Renew Wind Energy (Rajkot) Vs The Deputy Commissioner Of Private Limited,138, Ansal Income Tax, Circle 19(1) Delhi Chambers, Bhikajicama Palace, Range Code-44, C. R. New Delhi Building, I. P. Estate, Pan: Aafcr4553H New Delhi Appellant Respondent Assessee By Sh. Kashish Gupta, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 27/01/2026 Date Of Pronouncement 29/01/2026

passed within the extended period, as otherwise the extension becomes meaningless. (e) The outer time limit of 33 months in case of reference to TPO under Section 153, would not refer to draft order, but only to final order and hence, the entire proceedings would have to be concluded within

Fev India Private Limited, Delhi vs. Assessment Unit, National Faceless Assessment Centre

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahayfev India Private Limited V Assessment Unit B-260, Greater Kailash-1, New S National Faceless Delhi, South East, Delhi,110048 Assessment Centre, Income Pan: Aaacf9589Q Tax Department, New Delhi Appellant Respondent Assessee By Sh. Nikhil Tiwari, Ca (Virtual) Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 27/01/2026 Date Of Pronouncement 29/01/2026

passed within the extended period, as otherwise the extension becomes meaningless. (e) The outer time limit of 33 months in case of reference to TPO under Section 153, would not refer to draft order, but only to final order and hence, the entire proceedings would have to be concluded within

Johnson Matthey India Pvt. Ltd., New Delhi vs. ACIT Circle 13(1), New Delhi

In the result, appeals of the Assessees are allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwaljohnson Matthey India P. Ltd. Vs The Deputy Commissioner Of C/O. Luthra & Luthra Law Income Tax, Circle 13(2) Office India, 103, Ashoka Estate, Spm Civic Centre, New Delhi Barakhamba Road, New Delhi Pan: Aaacj2919A Appellant Respondent Johnson Matthey India P. Ltd. Vs National Faceless Appeal 5Th Floor, C/O Regus Business Centre, Income Tax Center, Gurgaon, Road, South Department West Delhi Pan: Aaacj2919A Appellant Respondent Assessee By Sh. Sumit Mangal, Adv, Ms. Radhika Sharma, Adv& Ms. Soumya Pandey, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 29/01/2026

otherwise the extension becomes meaningless. Johnson Matthey India P. Ltd. Vs. DCIT (e) The outer time limit of 33 months in case of reference to TPO under Section 153, would not refer to draft order, but only to final order and hence, the entire proceedings would have to be concluded

Google India Digital Services Private Limited, Delhi vs. Au, NFAC, ACIT(OSD), Range 42, Delhi

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahaygoogle India Digital Servicdes V Assessment Unit, Private Limited. 5Th Floor, Dlf S Nfac, Acit (Osd), Range Centre Block, 124, Sansad Marg, 42, C. R. Building, H. O. Central Delhi, New Delhi New Delhi Pan: Aagcg6803L Appellant Respondent Assessee By Sh. Kanchan Kaushal, Ar Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 27/01/2026 Date Of Pronouncement 29/01/2026

passed within the extended period, as otherwise the extension becomes meaningless. (e) The outer time limit of 33 months in case of reference to TPO under Section 153, would not refer to draft order, but only to final order and hence, the entire proceedings would have to be concluded within

General Motors India Private Limited, Haryana vs. Circle-1(1), Gurgaon

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahay

1 ITA No. 800/Del/2022 General Motors India (P.) Ltd. IN THE INCOME TAX APPELLATE TRIBUNAL DELHI (DELHI BENCH ‘H’ NEW

Groupe Seb India Pvt Ltd, Gurugram vs. ACIT, (OSD), New Delhi

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahaygroupe Seb India Pvt. Ltd. Vs Acit (Osd) Vipul Plaza, 215-220, Golf Course Range-10, C. R. Building, Road Suncity, Sector-54, Gurgaon, New Delhi Haryana Pan: Aagcm6857L Appellant Respondent Assessee By Ms. Shruti Khimta, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 28/01/2026 Date Of Pronouncement 29/01/2026

passed within the extended period, as otherwise the extension becomes meaningless. (e) The outer time limit of 33 months in case of reference to TPO under Section 153, would not refer to draft order, but only to final order and hence, the entire proceedings would have to be concluded within

Ball Beverage Packaging(India) Pvt Ltd, Bangalore vs. DCIT, Circle-4 (2), Delhi

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Krinwant Sahayball Beverage Packaging (India) Pvt. V Dcit, Circle-4(2) Ltd. B-302, 3Rd Floor B Wing Brigade S New Delhi-110002 Magnum, Amruthali, Nh-7, International Airport Road, Bangaluru, Not Listed, 560092 Pan: Aabch77101B Appellant Respondent Assessee By Ms. Snigdha Gautam, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 22/01/2026 Date Of Pronouncement 29/01/2026

passed within the extended period, as otherwise the extension becomes meaningless. (e) The outer time limit of 33 months in case of reference to TPO under Section 153, would not refer to draft order, but only to final order and hence, the entire proceedings would have to be concluded within

Haskoningdhv Consulting Pvt Ltd, Delhi vs. ACIT, Circle-10(1), Delhi

Bench: Shri Vikas Awasthy & Shri Sanjay Awasthiआ.अ.सं/.I.T.A No.5517/Del/2024 िनधा"रणवष"/Assessment Year: 2021-22 बनाम Airbnb Payments India Private Limited, The Dcit Circle 1(1), Level 9, Spaze I Tech Park, A1 Tower,Sector Vs. Gurugram,Haryana. 49, Sohna Road, Gurugram, Haryana.India. Pan No. Aanca6203B अपीलाथ" Appellant ""यथ"/Respondent

passed within the extended period, as otherwise the extension becomes meaningless. (e) The outer time limit of 33 months in case of reference to TPO under Section 153, would not refer to draft order, but only to final order and hence, the entire proceedings would have to be concluded within