“resale price method”

M/S. BOSE CORPORATION INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, both the appeals of the assessee are allowed

Bench: Shrivikas Awasthy & Shrisanjay Awasthiआ.अ.सं/.I.T.A Nos.1595 & 1596/Del/2017 िनधा"रणवष"/Assessment Years: 2007-08 & 2008-09 बनाम Bose Corporation India P. Ltd., Acit, Salcon Aurum, 3Rd Floor, Plot No.4, Vs. Circle 5(1), Room No.390, Jasola District Centre, C.R. Building, I.P. Estate, New Delhi. New Delhi. Pan No.Aaacb3260A अपीलाथ" Appellant ""यथ"/Respondent

company a Transfer Pricing study by the assessee himself his activities have been characterized as buy sale distributor. The assessee selected the Resale Price Method (hereafter as RPM) to benchmark its support services income and purchase of finished goods. It may be mentioned that its AMP expenses had not been ... further submission that following the Sony Ericsson case (supra) (paras 165 and 166 thereon) once an International Transaction was bench- marked using Resale Price Method (RPM) as the most appropriate method, then there would be no need to benchmark the AMP expenses separately. It was averred that if the adjusted

M/S. BOSE CORPORATION INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, both the appeals of the assessee are allowed

company a Transfer Pricing study by the assessee himself\nhis activities have been characterized as buy sale distributor. The\nassessee selected the Resale Price Method (hereafter as RPM) to\nbenchmark its support services income and purchase of finished goods. It\nmay be mentioned that its AMP expenses had not been ... nfurther submission that following the Sony Ericsson case (supra) (paras\n165 and 166 thereon) once an International Transaction was bench-\nmarked using Resale Price Method (RPM) as the most appropriate\nmethod, then there would be no need to benchmark the AMP expenses\nseparately. It was averred that if the adjusted

SWATCH GROUP (INDIA) PRIVATE LIMITED,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 22(2), C.R. BUILDING

In the result, the appeal of the assessee is partly allowed

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh[Assessment Year: 2021-22] Swatch Group (India) Private Deputy Commissioner Of Income Limited, Tax, 4Th Floor, Rectangle-I, Plot No. D- Vs Circle 22(2), 4, Saket District Centre, C.R. Building, I.P. Estate, Delhi, New Delhi-110017. 110002. Pan- Aafcs7516R Assessee Revenue

functions performed by such persons or such other relevant factors as the Board may prescribed namely: - (a)comparable uncontrolled price method; (b) resale price method; (c) cost plus method; (d) profit split method; (e)Transaction net margin method; (f) Any other method provided in Rule 10AB; (g) Further, other methods

SPECTRIS TECHNOLOGIES PVT. LTD.,GURGAON vs. ITO, NEW DELHI

In the result, this appeal is partly allowed

Bench: Shriyogesh Kumar Us & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.3742/Del/2015 िनधा"रणवष"/Assessment Year: 2009-10 बनाम Spectris Technologies P. Ltd. Income Tax Officer, 201-B, Second Floor, Vs. Ward-9(1), Park Centra, Sector-30, New Delhi. Gurgaon. Pan No.Aagcs6654R अपीलाथ" Appellant ""यथ"/Respondent

wide approach by treating Indenting / Marketing support segment and Trading of spare parts (AMC) segment as single business segment. 2 3.2 Rejecting the Resale Price Method adopted by the Appellant and instead adopting Transaction Net Margin Method (TNMM) as the most appropriate method for benchmarking the international transactions under Trading

DCIT, NEW DELHI vs. M/S. EXXON MOBIL LUBRICANTS PVT. LTD., NEW DELHI

In the result, appeal of the Revenue is party allowed

assessee before ld.\nCIT(A).\n6. Regarding import of additives, import of lubricants, sale of Marine\nLubricants, marketing support services, assessee has taken Resale Price Method\n(RPM) as MAM. In this regard, ld. CIT-DR submits that TPO at page 10 &11 of its\norder has given specific reasons ... Assessment Year 2004-05, in remand proceeding, the TPO accepted the arm's\nlength price computed by the assessee under trading segment on resale price method.\nHe, therefore, submits that adjustments made in arm's length price has rightly been\ndeleted by ld. CIT(A) and such order deserves

LUXOTTICA INDIA EYEWEAR PVT. LTD.,GURGAON vs. ACIT, NEW DELHI

Appeal of the assessee is allowed for statistical purposes

Bench: Ms. Madhumita Roy & Shri Manish Agarwalluxottica India Eyewear Pvt. Ltd., Asst. Cit, 7Th Floor, Dlf Building No.9, Circle-15(2), Tower-B, Phase-Iii, Dlf Cyber Vs. New Delhi. City, Gurgaon-122002, Haryana. Pan-Aabcl3871C (Appellant) (Respondent) Assessee By Ms. Tanmayee Rajkumar, Adv., Ca Department By Shri Dheeraj Kumar Jaiswal, Sr. Dr Date Of Hearing 28.10.2025 Date Of Pronouncement 31.12.2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Final Assessment Order Dated 30.01.2015 Passed U/S 143(3) R.W.S.144C(1) Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’) In Compliance To The Direction Given By Ld. Dispute Resolution Panel (Drp) Vide Order Dated 15.12.2014 For Asst. Year 2010-11. 2. In The Present Appeal, The Co-Ordinate Bench Vide Order Dated 26.05.2017 In Ita No.1492/Del/2015 Has Remand The Issue Of Tp Adjustment Towards Alleged Amp Expenses To The File Of Tpo To Decide Afresh With Certain Directions, However, Luxottica India Eyewear Pvt. Ltd. Vs. Acit Ground In Respect Of Tp Adjustment Made Towards International Transactions Of Import Of Finished Goods Remained Un-Adjudicated.

finished goods. The said grounds are set out below: "4.1 That the action of Hon'ble DRP/Ld. AO/Ld. TPO of rejecting the Resale Price Method ("RPM") applying Transaction Net Margin Method ("TNMM") as the Most appropriate Method ("MAM") under section 92C of the Act to determine ALP of impugned international ... assessee itself in Assessment Year 2009-10 in IT(TP)A No.1115/Del/2014 wherein vide order dated 06.05.2014, Co-ordinate Bench has held that “Resale Price Method” as most appropriate method (MAM). The Co-ordinate Bench further directed the TPO to adopt the ‘Resale Price Method’ as MAM and compute

SPECTRIS TECHNOLOGIES PVT. LTD.,GURGAON vs. ACIT, NEW DELHI

In the result, the appeal of the assessee is allowed for statistical purpose with above observations

Bench: Shri C.N. Prasad & Shri Naveen Chandra[Assessment Year: 2008-09] Spectris Technologies Pvt. Vs. Acit Ltd., 201-B, Second Floor, New Delhi Park Centra, Sector -30 Gurgaon Pan No. Aagcs6654R Appellant Respondent Assessee By Sh. Tarandeep Singh, Advocate Revenue By Ms. Priya Goel, Sr. Dr Date Of Hearing 10.10.2025 Date Of Pronouncement 17.12.2025 Order Per C.N. Prasad, Jm, This Appeal Is Filed By The Assessee Against The Order Of The Ld.Commissioner Of Income Tax (Appeals) -20, New Delhi Vide Order Dated 27.03.2014 For The A.Y. 2008-09. The Assessee Has Raised Following Grounds :- 1. That On The Facts & Circumstances Of The Case & In Law, The Order Passed By The Ld. Commissioner Of Income-Tax (Appeals)-Xx, New Delhi ("Cit(A)") Is Bad In Law.

instead treating the provision of market agency services and provision of AMC services together as a single business segment. 3.2 Rejecting the Resale Price Method adopted by the Appellant in favour of Transaction Net Margin Method (TNMM) as the most appropriate method for benchmarking the international transactions under AMC segment

ECOENERGY INSIGHTS LTD ( FORMERLY KNOWN AS CHUBB ALBA CONTROL SYSTEMS P.LTD),NEW DELHI vs. DCIT, CIRCLE-4(2), NEW DELHI

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

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaecoenergy Insights Ltd., Vs. Dcit, (Formerly Known As Chubb Alba Control Circle 4 (2), Systems P. Ltd.), New Delhi. Ground Floor, 18, Netaji Subhash Marg, Daryaganj, New Delhi – 110 002. (Pan :Aaaca0031C) (Appellant) (Respondent) Assessee By : Shri Nageshwar Rao, Advocate Shri Parth, Advocate Shri Pratik Rath, Advocate Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 12.08.2025 Date Of Order : 10.11.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Assessment Order Dated 25.07.2022Passed By The Assessment Unit, Income Tax Department Under Section 147 Read With Section 144C(13) R.W.S. 144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Ay 2018-19 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act.

thereby erred in selecting Transaction Net Margin Method ("TNMM") as the Most Appropriate Method ("MAM") to benchmark the impugned international transaction instead of Resale Price Method ("RPM", which was more suitable in the case. 17. Without prejudice to any of the grounds, while applying TNMM as the MAM, the TPO/AO/DRP ... goods worth INR 8.25 crores were imported. Detailed FAR is discussed in pages 58 to 60 of said TP Study. Basis for choosing Resale price method (RPM) can be found at pages 67 to 71 where at it is concluded that in comparison to 6 companies selected for benchmarking, this

JUNIPER NETWORKS SOLUTION INDIA PRIVATE LIMITED,NEW DELHI vs. ASSESSMENT UNIT, NFAC ITD, NEW DELHI

In the result, ground no 3 raised by the assessee is allowed in its favour

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Juniper Networks Solution India Pvt. Ltd., Vs. Assessment Unit, Unit No.Iia, 06Th Floor, Dlf Centre, Nfac Itd, Parliament Street, Connaught Place, New Delhi – 110 001. (Pan : Aaecj1345A) (Appellant) (Respondent) Assessee By : Shri Sachit Jolly, Sr. Advocate Shri Sandeep Bhalla, Advocate Shri Anurag Singhal, Ca Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 05.08.2025 Date Of Order : 24.10.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Assessment Order Dated 27.07.2024 Passed By The Income Tax Department, Assessment Unit U/S 143(3) Read With Section 144C(13)/144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2020-21 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act.

circumstances of the case and in law, the Ld. DRP has erred in upholding action of the Assessing Officer/Ld. TPO in:  not considering Resale Price Method ('RPM') as the most appropriate method for benchmarking the international transaction related to purchase of traded goods under the alleged trading segment. The Appellant

HUAWEI TELECOMMUNICATIONS (INDIA) COMPANY PVT. LTD.,GURGAON vs. DCIT, CIRCLE- 2(1), GURGAON

In the result, the appeal of assessee is allowed

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2014-15 Huawei Telecommunications Vs. Dcit, (India) Company Pvt. Ltd., Circle 2(1), 7Th Floor, Tower-A, Spaze-1- Gurgaon Tech Park, Sohna Road, (Haryana) Gurgaon, Haryana Pin: 122 001 Aabch1376E (Appellant) (Respondent)

appreciating the fact that the international transaction pertaining to import of equipment satisfies the arm's length principle even upon application of Resale Price Method ("RPM"). 14. Without prejudice to the above, the learned AO/TPO/ Hon'ble DRP erred in not restricting the adjustment made to appellant's equipment distribution

PANASONIC INDIA PRIVATE LTD.,GURGAON vs. NEAC, NEW DELHI

In the result, the appeal of the assessee is partly allowed

Bench: Shri C. N. Prasad & Shri M. Balaganeshpanasonic India Pvt. Ltd, Vs. Neac, 12Th Floor, Ambience New Delhi Corporate Office, Tower-2, Ambience Island, Gurgaon (Appellant) (Respondent) Pan: Aadcp9391B

Holdings Corporation and SANYO Electric Co., Ltd., by INR 1,343,635,463 and in doing so have grossly erred in: 3.1. rejecting Resale Price Method (RPM') as adopted by the Appellant and applying Transactional Net Margin Method (TNMM') as the most appropriate method for benchmarking the international transaction ... employed to add value to these traded goods by the assessee. The assessee benchmarked the international transaction in its distribution segment by using Resale Price Method (RPM) as the Most Appropriate Method (MAM) by adopting the Profit Level Indicator (PLI) as GP /Sales. The assessee in its Transfer Pricing Study

WIPRO GE HEALTHCARE PVT. LTD.,BANGALORE vs. DCIT, NEW DELHI

In the result, the Appeal o f the Assessee is partly allowed

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Wipro Ge Healthcare Pvt. Ltd. Vs. Dcit (Earlier Know As Ge Healthd Care Circle12(1) Pvt. Ltd.) 4, Kadugodi, Industrial New Delhi Area, Bangalore,Pan: Aaacw1685J Appellant Respondent Assessee By Sh. Sachit Jolly, Sr. Adv, Sh. Viyustirawat, Adv& Sh. Devansh Jain, Adv Revenue By Sh. S. K. Jadhav, Cit(Dr) Date Of Hearing 05/08/2025 Date Of Pronouncement 12/09/2025

determination of the arm's length margin. 7.5 In making general statements and specious reasoning, without providing any supporting evidence, regarding inapplicability of Resale Price Method ("RPM") for the distribution segment and not appreciating that these stated observations do not impair the applicability of RPM in light of the facts