“international transaction”

Calsonic Kansei Motherson Auto Products Private Limited, New Delhi vs. Assistant/Deputy Commissioner of Income Tax, New Delhi

Bench: Shri Prakash Chand Yadav & Shri Manish Agarwal

declaring the same income as was declared originally. Thereafter, the case of the assessee was selected for scrutiny. As the instant case was having international transactions with its AE. The Assessing Officer made a reference to the TPO in accordance with TP provisions. Thereafter, the Ld. TPO computed ... Length Price (ALP) o the international transactions entered into by the assessee. After the receipt of TPO order, the Ld. Assessing Officer framed the draft assessment order against which the assessee filed objections before the DRP and the Ld. DRP vide its order dated 25th June 2024 restored the issue

Genpact Services Llc, Gurgaon vs. Assistant Commissioner of Income Tax Circle - Int Tax 1(3)(1), Delhi

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

reference u/s 92CA of the Act to the Transfer Pricing Officer (TPO') to determine the Arm's Length Price (‘ALP') in respect of International transaction entered into by the assessee. 2. 1. The ld. TPO proposed an adjustment of Rs.9,32,12,889/- in his order passed u/s 92CA ... this regard, the assessee filed a written submission in support of which is reproduced as under: (a) During the relevant AY, the Appellant undertook international transaction of 'receipt' of support services' with its AE, namely, Genpact India Private Limited, which comprised of certain support services in the nature of technology

Kohinoor Foods Ltd., Faridabad vs. ACIT, Circle-14(2), New Delhi

In the result, all the appeals of the assessee are allowed as indicated above

Bench: Shri Prakash Chand Yadav & Shri Manish Agarwal

30th November, 2012. The case of the assessee was thereafter selected for scrutiny and the matter was referred to the TPO on account of international transaction entered into between the assesse and its AE abroad. Thereafter, the Ld. TPO made certain adjustments with respect to the international transactions and sent ... deleted the addition made by the AO in respect of domestic transactions and the CIT(A) has sustained the additions of international transactions. 5. Still aggrieved with the order of the Ld. CIT(A), the assessee has come up in appeal before us and has raised three basic issues

Kohinoor Foods Ltd., Faridabad vs. DCIT Central Circle-28, New Delhi

In the result, all the appeals of the assessee are allowed as indicated above

Bench: Shri Prakash Chand Yadav & Shri Manish Agarwal

30th November, 2012. The case of the assessee was thereafter selected for scrutiny and the matter was referred to the TPO on account of international transaction entered into between the assesse and its AE abroad. Thereafter, the Ld. TPO made certain adjustments with respect to the international transactions and sent ... deleted the addition made by the AO in respect of domestic transactions and the CIT(A) has sustained the additions of international transactions. 5. Still aggrieved with the order of the Ld. CIT(A), the assessee has come up in appeal before us and has raised three basic issues

Kohinoor Foods Ltd, Faridabad vs. ACIT Circle-14(2), New Delhi

In the result, all the appeals of the assessee are allowed as indicated above

Bench: Shri Prakash Chand Yadav & Shri Manish Agarwal

30th November, 2012. The case of the assessee was thereafter selected for scrutiny and the matter was referred to the TPO on account of international transaction entered into between the assesse and its AE abroad. Thereafter, the Ld. TPO made certain adjustments with respect to the international transactions and sent ... deleted the addition made by the AO in respect of domestic transactions and the CIT(A) has sustained the additions of international transactions. 5. Still aggrieved with the order of the Ld. CIT(A), the assessee has come up in appeal before us and has raised three basic issues

Acme Cleantech Solutions Private Limited, Gurgaon vs. DCIT, Circle-1(1), New Delhi

In the result, both the appeals of the assessee are partly allowed as indicated above

Bench: SHRI PRAKASH CHAND YADAV (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

India as well M/s Acme Cleantech Solutions Pvt. Ltd. vs. NFAC as overseas. During the year under consideration, the assessee has entered into international transactions with its Associated Enterprises (AE). Observing this fact the AO made a reference to the TPO. The Ld. TPO vide its order dated 7th February ... computed the Arm’s Length Price (ALP) of the international transactions after making certain adjustment and restore the matter to the file of AO. Thereafter, the AO passed the draft assessment order, against which the assessee filed its objection before the DRP and the Ld. DRP vide its order dated

Acme Cleantech, Haryana vs. ACIT, Circle-1 (1), New Delhi

In the result, both the appeals of the assessee are partly allowed as indicated above

Bench: SHRI PRAKASH CHAND YADAV (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

India as well M/s Acme Cleantech Solutions Pvt. Ltd. vs. NFAC as overseas. During the year under consideration, the assessee has entered into international transactions with its Associated Enterprises (AE). Observing this fact the AO made a reference to the TPO. The Ld. TPO vide its order dated 7th February ... computed the Arm’s Length Price (ALP) of the international transactions after making certain adjustment and restore the matter to the file of AO. Thereafter, the AO passed the draft assessment order, against which the assessee filed its objection before the DRP and the Ld. DRP vide its order dated

Fresenius Kabi Oncology Ltd, New Delhi vs. ITO, Ward-9(3), New Delhi

In the result appeal of the assessee is allowed

Bench: Shri Prakash Chand Yadav & Shri Manish Agarwalfresenius Kabi Oncology Ltd. Income Tax Officer, B-310, Som Dutt Chamber, Ward-9(3), Bhikaji Cama Place, Vs. New Delhi. New Delhi-110066. Pan-Aabcd7720L (Appellant) (Respondent)

erred on facts and in law in making an adjustment of Rs.105,07,00,000 to the arm's length price of 'international transactions' of sale of APIs and formulations, undertaken by the Appellant with the Associated Enterprises ("AEs"), on the basis of the order passed under section 92CA ... Dispute Resolution Panel ("DRP"). 3.1 That the AO/TPO/DRP erred on facts and in law in considering the Appellant as the tested party for benchmarking international transaction of provision of sale of APIs and formulations, applying TNMM, not appreciating that the Appellant being the manufacturer of such formulations, undertaking complex operations

DCIT, Circle- 5(2), New Delhi vs. Carlsberg India Pvt. Ltd., New Delhi

In the result, the appeal filed by the assessee is allowed and appeal filed by the Revenue stands dismissed

Bench: Shri Prakash Chand Yadav & Shri Manish Agarwalcarlsberg India Private Limited, Dy. Cit, 4Th Floor, Rectangle No.1, Circle-5(2), Commercial Complex,D-4, Saket, Vs. New Delhi. New Delhi-110017. Pan-Aajcs8454J (Appellant) (Respondent) (Assessment Year 2010-11 Dy. Cit, Carlsberg India Private Circle-5(2), Limited, New Delhi. Vs. 4Th Floor, Rectangle No.1, Commercial Complex, D-4, Saket, New Delhi-110017. Pan-Aajcs8454J (Appellant) (Respondent) Assessee By Shri S.K. Aggarwal, Ca & Shri Paras Sharma, Ar & Ms. Ruchika Mittal, Ca Department By Shri S.K. Jadhav, Cit-Dr Date Of Hearing 28/07/2025 Date Of Pronouncement 31/07/2025 Order

return of income filed by the assessee was processed u/s 143(1) of the Income Tax Act, and, thereafter, selected for scrutiny. Since, international transactions were involved in this case. The matter was referred to the TPO for computing Arm’s Length Price (ALP) of the transactions entered ... concept of overseas AES adopted as the tested party in the Appellant's own case, the same treatment shall be given to the International transactions, which are also same in this year. 9.36 I find that in the present case, the agreement clearly provides a direction

Carlsberg India Pvt. Ltd., New Delhi vs. DCIT, Circle- 5(2), New Delhi

In the result, the appeal filed by the assessee is allowed and appeal filed by the Revenue stands dismissed

Bench: Shri Prakash Chand Yadav & Shri Manish Agarwalcarlsberg India Private Limited, Dy. Cit, 4Th Floor, Rectangle No.1, Circle-5(2), Commercial Complex,D-4, Saket, Vs. New Delhi. New Delhi-110017. Pan-Aajcs8454J (Appellant) (Respondent) (Assessment Year 2010-11 Dy. Cit, Carlsberg India Private Circle-5(2), Limited, New Delhi. Vs. 4Th Floor, Rectangle No.1, Commercial Complex, D-4, Saket, New Delhi-110017. Pan-Aajcs8454J (Appellant) (Respondent) Assessee By Shri S.K. Aggarwal, Ca & Shri Paras Sharma, Ar & Ms. Ruchika Mittal, Ca Department By Shri S.K. Jadhav, Cit-Dr Date Of Hearing 28/07/2025 Date Of Pronouncement 31/07/2025 Order

return of income filed by the assessee was processed u/s 143(1) of the Income Tax Act, and, thereafter, selected for scrutiny. Since, international transactions were involved in this case. The matter was referred to the TPO for computing Arm’s Length Price (ALP) of the transactions entered ... concept of overseas AES adopted as the tested party in the Appellant's own case, the same treatment shall be given to the International transactions, which are also same in this year. 9.36 I find that in the present case, the agreement clearly provides a direction