RENAULT INDIA PRIVATE LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, appeal of the assessee is partly allowed

Bench: Shri Abraham P.George & Shri George Mathanआयकर अपील सं./I.T.A. No. 1078/Mds/2017 "नधा"रण वष" /Assessment Year : 2012-2013. M/S. Renault India Private Vs. The Deputy Commissioner Of Limited, Income Tax, No.37 & 38, Asv Ramana Corporate Circle 5(1) Towers, Chennai. 4Th Floor, Venkatnarayana Road, T.N Agar, Chennai 600 017. [Pan Aadcr 2042M ] (अपीलाथ"/Appellant) (""यथ"/Respondent)

transfer pricing adjustment is to substitute the :- 29 -: transaction price with the arm's length price so determined. The second proviso to section 92C(2

HOSPIRA HEALTHCARE INDIA PRIVATE LIMITED,CHENNAI vs. DCIT, CHENNAI

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.469/Chny/2017 िनधा<रण वष< /Assessment Year: 2012-13 M/S. Hospira Healthcare India The Dy. Commissioner Of Pvt. Ltd., Vs. Income Tax, Sri-Nivas, New No.86 (Old No.89), Corporate Circle-2(2), Gn Chetty Road, T Nagar, Chennai. Chennai – 600 017. [Pan: Aaabco 2190F] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Shri Sriram Seshadri, C.A Jkथ" की ओर से /Respondent By : Shri A. Sasikumar, Cit सुनवाई की तारीख/Date Of Hearing : 25.04.2024 घोषणा की तारीख /Date Of Pronouncement : 22.07.2024 आदेश / O R D E R Per Jagadish, A.M : Aforesaid Appeal Filed By The Assessee Against The Assessment Order Passed By The Dcit, Corporate Circle-2(2), Chennai U/S.143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 (Hereinafter “The Act”) For The Assessment Year 2012-13, In Pursuance Of The Directions Issued By The Dispute Resolution Panel, Bengalore (Hereinafter ‘Drp’) Vide Directions Dated 09.11.2016. :- 2 -:

2) of section 92C, the arm's length price in relation to an international transaction … shall be determined by any of the following methods, being the most appropriate method, in the following manner, namely’. :- 21 -: Clause (a) of rule 10B(1) prescribes the manner of determination of the ALP under the CUP method, which reads as under: “(a) comparable uncontrolled

DCIT, CHENNAI vs. FLAKT (INDIA) LTD., CHENNAI

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No.1032/Mds/2014 "नधा"रण वष" / Assessment Year : 2009-10

Section 92C of the Income-tax Act, 1961 (in short 'the Act'). The assessee has adopted Transaction Net 6 I.T.A. No.1032/Mds/14 Margin Method as most appropriate method for the purpose of transfer pricing adjustment. For the purpose of Transaction Net Margin Method, the net profit margin realized by the enterprises from international transaction entered with Associate Enterprise, is computed

DOOWON AUTOMOTIVE SYSTEMS INDIA PRIVATE LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No.1016/Mds/2015 "नधा"रण वष" / Assessment Year : 2010-11 M/S Doowon Automotive Systems India Pvt. Ltd., The Deputy Commissioner Of Plot No.B-19 & 20, Sipcot V. Income Tax, Industrial Park, Oragadam, Corporate Circle – 1(1), Sriperumbudur Taluk, Chennai - 600 034. Kancheepuram District-602 105. Pan : Aaccd 4172 F (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 92C of the Act. 10. In respect of the Customs duty adjustment and working capital employed, the Dispute Resolution Panel has simply placed its reliance on its own order in the assessee's own case for assessment year 2009-10. This Tribunal examined the directions of the Dispute Resolution Panel in the assessee's own case for assessment year

POLARIS CONSULTING & SERVICES LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the assessee’s appeal for assessment year

Bench: Shri N.R.S. Ganesan & Shri Sanjay Aroraआयकर अपील सं./Ita No.1218/Mds/2016 "नधा"रण वष" / Assessment Year : 2010-11 & आयकर अपील सं./Ita No.615/Mds/2016 "नधा"रण वष" / Assessment Year : 2011-12

transfer pricing as provided in Indian Income-tax Act. Section 92B of the Act defines “international transaction”. “Associated Enterprise” is defined in Section 92A of the Act. Rule 10B of Income-tax Rules, 1962 provides most appropriate method for determination of arm's length price. Rule 10B(1)(e) provides method for determination of arm's length price by adopting

POLARIS SOFTWARE LAB LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the assessee’s appeal for assessment year

Bench: Shri N.R.S. Ganesan & Shri Sanjay Aroraआयकर अपील सं./Ita No.1218/Mds/2016 "नधा"रण वष" / Assessment Year : 2010-11 & आयकर अपील सं./Ita No.615/Mds/2016 "नधा"रण वष" / Assessment Year : 2011-12

transfer pricing as provided in Indian Income-tax Act. Section 92B of the Act defines “international transaction”. “Associated Enterprise” is defined in Section 92A of the Act. Rule 10B of Income-tax Rules, 1962 provides most appropriate method for determination of arm's length price. Rule 10B(1)(e) provides method for determination of arm's length price by adopting

DCIT, CHENNAI vs. POLARIS CONSULTING & SERVICES P LTD., CHENNAI

In the result, the assessee’s appeal for assessment year

Bench: Shri N.R.S. Ganesan & Shri Sanjay Aroraआयकर अपील सं./Ita No.1218/Mds/2016 "नधा"रण वष" / Assessment Year : 2010-11 & आयकर अपील सं./Ita No.615/Mds/2016 "नधा"रण वष" / Assessment Year : 2011-12

transfer pricing as provided in Indian Income-tax Act. Section 92B of the Act defines “international transaction”. “Associated Enterprise” is defined in Section 92A of the Act. Rule 10B of Income-tax Rules, 1962 provides most appropriate method for determination of arm's length price. Rule 10B(1)(e) provides method for determination of arm's length price by adopting

DCIT, CHENNAI vs. THE OFFICIAL LIQUIDATOR M/S. MASCON GLOBAL LTD. (IN LIQUIDATION), CHENNAI

Accordingly, the ground raised by the Revenue is dismissed

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

Transfer Pricing Officer-III, Chennai as required under section 92CA(1) of the Act. The TPO determined the arms length price at ₹. 239.54 crores and shortfall in the operating profit at ₹. 32.63 crores. This shortfall was directed to be brought to tax as per section 92C(4) of the Act. 3.2 On appeal, it was the submission before

DCIT, CHENNAI vs. THE OFFICIAL LIQUIDATOR M/S. MASCON GLOBAL LTD. (IN LIQUIDATION), CHENNAI

Accordingly, the ground raised by the Revenue is dismissed

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

Transfer Pricing Officer-III, Chennai as required under section 92CA(1) of the Act. The TPO determined the arms length price at ₹. 239.54 crores and shortfall in the operating profit at ₹. 32.63 crores. This shortfall was directed to be brought to tax as per section 92C(4) of the Act. 3.2 On appeal, it was the submission before

ACIT, CHENNAI vs. M/S. MASCON GLOBAL LTD., CHENNAI

Accordingly, the ground raised by the Revenue is dismissed

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

Transfer Pricing Officer-III, Chennai as required under section 92CA(1) of the Act. The TPO determined the arms length price at ₹. 239.54 crores and shortfall in the operating profit at ₹. 32.63 crores. This shortfall was directed to be brought to tax as per section 92C(4) of the Act. 3.2 On appeal, it was the submission before

DCIT, CHENNAI vs. THE OFFICIAL LIQUIDATOR M/S. MASCON GLOBAL LTD. (IN LIQUIDATION), CHENNAI

Accordingly, the ground raised by the Revenue is dismissed

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

Transfer Pricing Officer-III, Chennai as required under section 92CA(1) of the Act. The TPO determined the arms length price at ₹. 239.54 crores and shortfall in the operating profit at ₹. 32.63 crores. This shortfall was directed to be brought to tax as per section 92C(4) of the Act. 3.2 On appeal, it was the submission before

TITAN COMPANY LIMITED,HOSUR vs. ACIT, CHENNAI

In the result, both the appeals filed by the assessee are allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble S.R. Raghunathaआयकर अपील सं./ Ita No.393/Chny/2018 & आयकर अपील सं./ It(Tp)A No.89/Chny/2018 िनधा>रण वष> /Assessment Years: 2013-14 & 2014-15 Titan Company Ltd., The Dy. Commissioner Of Income No.3, Spicot Industrial Complex, Vs. Tax, Hosur, Krishnagiri – 635 126. Ltu-2, [Pan: Aaact 5131A] Chennai. (अपीलाथ"/Appellant) (""यथ"/Respondent)

2. The Hon'ble DRP/ learned Assessing Officer ('AO') / Transfer Pricing Officer (TPO) erred in ignoring the transfer pricing analysis undertaken by the Appellant in accordance with provisions of the Income-tax Act, 1961 ('the Act') read with Income-tax Rules, 1962 ('the Rules'). 3. The Hon'ble DRP / learned AO / TPO thereby erred in making an addition

HYUNDAI MOTOR INDIA LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

2(24), being a generic section, is not applicable in the context of transfer pricing and that income from an international transaction, as is the mandate of section 92, is to be computed having regard to arm’s length price. As regards the contention of the assessee that ‘brand building’, even if that be so, is not an international transaction

DCIT, CHENNAI vs. HYUNDAI MOTOR INDIA LIMITED, KANCHEEPURAM

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

2(24), being a generic section, is not applicable in the context of transfer pricing and that income from an international transaction, as is the mandate of section 92, is to be computed having regard to arm’s length price. As regards the contention of the assessee that ‘brand building’, even if that be so, is not an international transaction

DCIT, CHENNAI vs. HYUNDAI MOTOR INDIA LTD., KANCHEEPURAM

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

2(24), being a generic section, is not applicable in the context of transfer pricing and that income from an international transaction, as is the mandate of section 92, is to be computed having regard to arm’s length price. As regards the contention of the assessee that ‘brand building’, even if that be so, is not an international transaction

DCIT, CHENNAI vs. HYUNDAI MOTORS INDIA LTD., KANCHEEPURAM

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

2(24), being a generic section, is not applicable in the context of transfer pricing and that income from an international transaction, as is the mandate of section 92, is to be computed having regard to arm’s length price. As regards the contention of the assessee that ‘brand building’, even if that be so, is not an international transaction

HYUNDAI MOTOR INDIA LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

2(24), being a generic section, is not applicable in the context of transfer pricing and that income from an international transaction, as is the mandate of section 92, is to be computed having regard to arm’s length price. As regards the contention of the assessee that ‘brand building’, even if that be so, is not an international transaction

DURR INDIA PRIVATE LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, all the grounds of the appeal are treated as allowed for statistical purposes

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

2) of section 92C, the arm's length price in relation to an international transaction or a specified domestic transaction shall be determined by any of the following methods, being the most appropriate method, in the following manner, namely :- (a) comparable uncontrolled price method, by which,- (i) the price charged or paid for property transferred