“advance pricing agreement”

DCIT, Circle- 11(1), New Delhi vs. Honeywell International (India) Pvt. Ltd., New Delhi

In the result, appeal of the assessee for assessment year 2011 – 12 is partly allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing) M/S. Honeywell International Vs. Addl Cit (India) Pvt. Ltd, 1St Floor, Range-4, Unitech Trade Centre, New Delhi Sector-43, Block C, Sushant Lok Phase-I, Gurgaon Pan: Aanca7954K (Appellant) (Respondent) Addl Cit, Vs. M/S. Honeywell Special Range-4, International (India) Pvt. Ltd, New Delhi 1St Floor, Unitech Trade Centre, Sector-43, Block C, Sushant Lok Phase-I, Gurgaon Pan: Aanca7954K (Appellant) (Respondent) Dcit, Vs. M/S. Honeywell Circle-11(1), International (India) Pvt. Ltd, New Delhi 1St Floor, Unitech Trade Centre, Sector-43, Block C, Sushant Lok Phase-I, Gurgaon Pan: Aanca7954K (Appellant) (Respondent) M/S. Honeywell International Vs. Dcit, (India) Pvt. Ltd, 1St Floor, Unitech Circle-11(1), Trade Centre, Sector-43, Block New Delhi C, Sushant Lok Phase-I, Gurgaon Pan: Aanca7954K (Appellant) (Respondent)

margin of 16% for the transactions with its Indian group entities, which similar to the profit margin agreed by the appellant in the Advance Pricing Agreement („APA‟). Common Grounds 9. On facts and in law, the Ld. AO has erred in initiating penalty proceedings under section ... submitted that for Assessment Year 2011-12 the ld CIT(A) after considering 16% marked up as agreed in the advance pricing agreement has reworked the cost to be allocated between 10A and non 10A units. He therefore, submitted that even if the same methodology applied in the year considering

Honeywell International (India) Pvt. Ltd., New Delhi vs. DCIT, Circle- 11(1), New Delhi

In the result, appeal of the assessee for assessment year 2011 – 12 is partly allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing) M/S. Honeywell International Vs. Addl Cit (India) Pvt. Ltd, 1St Floor, Range-4, Unitech Trade Centre, New Delhi Sector-43, Block C, Sushant Lok Phase-I, Gurgaon Pan: Aanca7954K (Appellant) (Respondent) Addl Cit, Vs. M/S. Honeywell Special Range-4, International (India) Pvt. Ltd, New Delhi 1St Floor, Unitech Trade Centre, Sector-43, Block C, Sushant Lok Phase-I, Gurgaon Pan: Aanca7954K (Appellant) (Respondent) Dcit, Vs. M/S. Honeywell Circle-11(1), International (India) Pvt. Ltd, New Delhi 1St Floor, Unitech Trade Centre, Sector-43, Block C, Sushant Lok Phase-I, Gurgaon Pan: Aanca7954K (Appellant) (Respondent) M/S. Honeywell International Vs. Dcit, (India) Pvt. Ltd, 1St Floor, Unitech Circle-11(1), Trade Centre, Sector-43, Block New Delhi C, Sushant Lok Phase-I, Gurgaon Pan: Aanca7954K (Appellant) (Respondent)

margin of 16% for the transactions with its Indian group entities, which similar to the profit margin agreed by the appellant in the Advance Pricing Agreement („APA‟). Common Grounds 9. On facts and in law, the Ld. AO has erred in initiating penalty proceedings under section ... submitted that for Assessment Year 2011-12 the ld CIT(A) after considering 16% marked up as agreed in the advance pricing agreement has reworked the cost to be allocated between 10A and non 10A units. He therefore, submitted that even if the same methodology applied in the year considering

M/S. Honeywell International (India) Pvt. Ltd., New Delhi vs. Addl. CIT (Inv.), New Delhi

In the result, appeal of the assessee for assessment year 2011 – 12 is partly allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing) M/S. Honeywell International Vs. Addl Cit (India) Pvt. Ltd, 1St Floor, Range-4, Unitech Trade Centre, New Delhi Sector-43, Block C, Sushant Lok Phase-I, Gurgaon Pan: Aanca7954K (Appellant) (Respondent) Addl Cit, Vs. M/S. Honeywell Special Range-4, International (India) Pvt. Ltd, New Delhi 1St Floor, Unitech Trade Centre, Sector-43, Block C, Sushant Lok Phase-I, Gurgaon Pan: Aanca7954K (Appellant) (Respondent) Dcit, Vs. M/S. Honeywell Circle-11(1), International (India) Pvt. Ltd, New Delhi 1St Floor, Unitech Trade Centre, Sector-43, Block C, Sushant Lok Phase-I, Gurgaon Pan: Aanca7954K (Appellant) (Respondent) M/S. Honeywell International Vs. Dcit, (India) Pvt. Ltd, 1St Floor, Unitech Circle-11(1), Trade Centre, Sector-43, Block New Delhi C, Sushant Lok Phase-I, Gurgaon Pan: Aanca7954K (Appellant) (Respondent)

margin of 16% for the transactions with its Indian group entities, which similar to the profit margin agreed by the appellant in the Advance Pricing Agreement („APA‟). Common Grounds 9. On facts and in law, the Ld. AO has erred in initiating penalty proceedings under section ... submitted that for Assessment Year 2011-12 the ld CIT(A) after considering 16% marked up as agreed in the advance pricing agreement has reworked the cost to be allocated between 10A and non 10A units. He therefore, submitted that even if the same methodology applied in the year considering

Addl. CIT, New Delhi vs. M/S. Honeywell International (India) Pvt. Ltd., Gurgaon

In the result, appeal of the assessee for assessment year 2011 – 12 is partly allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing) M/S. Honeywell International Vs. Addl Cit (India) Pvt. Ltd, 1St Floor, Range-4, Unitech Trade Centre, New Delhi Sector-43, Block C, Sushant Lok Phase-I, Gurgaon Pan: Aanca7954K (Appellant) (Respondent) Addl Cit, Vs. M/S. Honeywell Special Range-4, International (India) Pvt. Ltd, New Delhi 1St Floor, Unitech Trade Centre, Sector-43, Block C, Sushant Lok Phase-I, Gurgaon Pan: Aanca7954K (Appellant) (Respondent) Dcit, Vs. M/S. Honeywell Circle-11(1), International (India) Pvt. Ltd, New Delhi 1St Floor, Unitech Trade Centre, Sector-43, Block C, Sushant Lok Phase-I, Gurgaon Pan: Aanca7954K (Appellant) (Respondent) M/S. Honeywell International Vs. Dcit, (India) Pvt. Ltd, 1St Floor, Unitech Circle-11(1), Trade Centre, Sector-43, Block New Delhi C, Sushant Lok Phase-I, Gurgaon Pan: Aanca7954K (Appellant) (Respondent)

margin of 16% for the transactions with its Indian group entities, which similar to the profit margin agreed by the appellant in the Advance Pricing Agreement („APA‟). Common Grounds 9. On facts and in law, the Ld. AO has erred in initiating penalty proceedings under section ... submitted that for Assessment Year 2011-12 the ld CIT(A) after considering 16% marked up as agreed in the advance pricing agreement has reworked the cost to be allocated between 10A and non 10A units. He therefore, submitted that even if the same methodology applied in the year considering

ACIT, Circle-14(2), New Delhi vs. Knowledge Infrastructure Systems Pvt. Ltd., New Delhi

Bench: Shri Kuldip Singh & Shri Prashant Maharishi(Through Video Conferencing) Acit, Vs. Knowledge Infrastructure Systems Circle-14(2), Pvt. Ltd, New Delhi G-02, Salcom Aurum Complex, Jasola, New Delhi Pan: Aacck4380L (Appellant) (Respondent)

with respect to interest of loan and corporate guarantee. 5. At the time of hearing the ld AR submitted advance pricing agreement u/s 92CC of the Act dated 18.12.2017 wherein, in roll back years the impugned assessment years is covered. As per para No. 10 of that agreement, the assessee