BG EXPLORATION & PRODUCTION INDIA LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX DDIT/ADIT (INTERNATIONAL TAXATION ) CIRCLE-1, DEHRADUN

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

Bench: Shri R.K. Panda & Shri V.P. Raoassessment Years: 2016-17

transfer pricing adjustment of Rs.2,28,48,22,523 in total towards international transactions pertaining to payment of management service and unit charges, IM charges and payroll expenses to its AE. Ground No. 2: Erroneous rejection of Transactional Net Margin Method ("TNMM”) and selection of Comparable Uncontrolled Price ("CUP”) Method 2.1. The learned TPO / AO / DRP / have erred

BG EXPLORATION & PRODUCTION INDIA LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, DDIT/ADIT (INTERNATIONAL TAXATION), CIRCLE -1, DEHRADUN

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

28,05,028/- on account of inventory written off and also made certain addition/disallowances on account of depreciation. The assessee approached the DRP. The DRP, following its order for the preceding assessment years, upheld the addition made by the TPO by observing as under:- 2 “2.1 Grounds 1 to 7 relate to the transfer pricing adjustment proposed for the international

NATIONAL OILWELL VARCO PTE. LTD.,MUMBAI vs. DCIT (INTERNATIONAL TAXATION), DEHRADUN

In the result, captioned appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

28. It is respectfully submitted that the Hon'ble ITAT, Delhi, has consistently adopted a prudent and institutionally sound approach in matters where the assessee raises the preliminary issue of limitation involving the interplay of sections 144C and 153, by adjourning such matters sine die/deferring adjudication, noting that the controversy is pending consideration before the Hon'ble Supreme Court

NATIONAL OILWELL VARCO PTE LTD.,MUMBAI vs. DCIT (INTERNATIONAL TAXATION), DEHRADUN

In the result, captioned appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

28. It is respectfully submitted that the Hon'ble ITAT, Delhi, has consistently adopted a prudent and institutionally sound approach in matters where the assessee raises the preliminary issue of limitation involving the interplay of sections 144C and 153, by adjourning such matters sine die/deferring adjudication, noting that the controversy is pending consideration before the Hon'ble Supreme Court

NATIONAL OIL WELL VARCO PTE. LTD (FORMERLY KNOWN AS VARCO INTERNATIONAL PTE. LTD),MAHARASHTRA vs. THE DEPUTY DIRECTOR OF INCOME TAX CIRCLE-1( INTERNATIONAL TAXATION ), DEHRADUN

In the result, captioned appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

28. It is respectfully submitted that the Hon'ble ITAT, Delhi, has consistently adopted a prudent and institutionally sound approach in matters where the assessee raises the preliminary issue of limitation involving the interplay of sections 144C and 153, by adjourning such matters sine die/deferring adjudication, noting that the controversy is pending consideration before the Hon'ble Supreme Court

NATIONAL OILWELL VARCO PTE. LTD. (FORMERLY KNOWN AS VARCO INTERNATIONAL PTE LTD.),MUMBAI vs. DCIT (INTERNATIONAL TAXATION), CIRCLE-2, DEHRADUN

In the result, captioned appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

28. It is respectfully submitted that the Hon'ble ITAT, Delhi, has consistently adopted a prudent and institutionally sound approach in matters where the assessee raises the preliminary issue of limitation involving the interplay of sections 144C and 153, by adjourning such matters sine die/deferring adjudication, noting that the controversy is pending consideration before the Hon'ble Supreme Court

NATIONAL OILWELL VARCO PTE. LTD.,MUMBAI vs. DCIT (INTERNATIONAL TAXATION), CI9RCLE-2, DEHRADUN

In the result, captioned appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

28. It is respectfully submitted that the Hon'ble ITAT, Delhi, has consistently adopted a prudent and institutionally sound approach in matters where the assessee raises the preliminary issue of limitation involving the interplay of sections 144C and 153, by adjourning such matters sine die/deferring adjudication, noting that the controversy is pending consideration before the Hon'ble Supreme Court

SIME DARBY ENGINEERING SDN BHD,DELHI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), CIRCLE-1, DEHRADUN

In the result, appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

28. It is respectfully submitted that the Hon'ble ITAT, Delhi, has consistently adopted a prudent and institutionally sound approach in matters where the assessee raises the preliminary issue of limitation involving the interplay of sections 144C and 153, by adjourning such matters sine die/deferring adjudication, noting that the controversy is pending consideration before the Hon'ble Supreme Court

SIME DARBY ENGINEERING SDN BHD,GURGAON vs. DCIT (INTERNATIONAL TAXATION), CIRCLE-2, DEHRADUN

In the result, appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

28. It is respectfully submitted that the Hon'ble ITAT, Delhi, has consistently adopted a prudent and institutionally sound approach in matters where the assessee raises the preliminary issue of limitation involving the interplay of sections 144C and 153, by adjourning such matters sine die/deferring adjudication, noting that the controversy is pending consideration before the Hon'ble Supreme Court

SIME DARBY ENGINEERING SDNBHD,MALAYSIA vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION ) CIRCLE-1, DEHRADUN

In the result, appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

28. It is respectfully submitted that the Hon'ble ITAT, Delhi, has consistently adopted a prudent and institutionally sound approach in matters where the assessee raises the preliminary issue of limitation involving the interplay of sections 144C and 153, by adjourning such matters sine die/deferring adjudication, noting that the controversy is pending consideration before the Hon'ble Supreme Court

KARAM SAFETY PRIVATE LIMITED,UDHAM SINGH NAGAR vs. THE INCOME TAX OFFICER, WARD-2(3)(5), UDHAM SINGH NAGAR

In the result, both the appeals of the assessee are allowed and that of the Stay Applications are dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

Transfer Pricing Officer 3(2)(2) (“TPO”) for determination of arm’s length price of the specified domestic transactions (“SDT”) / international transactions undertaken by the Applicant. 9. The TPO vide order dated 30 January 2019 held that the applicant has earned more than ordinary profits from its Section 80-IC business and proposed an adjustment of Rs.5

KARAM SAFETY PRIVATE LIMITED,SITARGANJ vs. THE INCOME TAX OFFICER, WARD-2(3)(5), UDHAM SINGH NAGAR

In the result, both the appeals of the assessee are allowed and that of the Stay Applications are dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

Transfer Pricing Officer 3(2)(2) (“TPO”) for determination of arm’s length price of the specified domestic transactions (“SDT”) / international transactions undertaken by the Applicant. 9. The TPO vide order dated 30 January 2019 held that the applicant has earned more than ordinary profits from its Section 80-IC business and proposed an adjustment of Rs.5

ACIT, CIRCLE- 2, INTERNATIONAL TAXATION, DEHRADUN vs. SOLAR TURBINES INTERNATIONAL CO., BENGALURU

In the result, the appeal of the Revenue is dismissed

Bench: Dr. B.R.R. Kumar & Sh. Yogesh Kumar U.S.Assessment Year: 2014-15 Solar Turbines International Vs Dcit, Company (Singapore Branch Of Circle-2, Solar Turbines International International Taxation, Company, Usa), Dehradun. 14 Tractor Road, Singapore, C/O Delloitte Haskins & Sells Llp, Deloitte Centre Anchorage- Ii, Richmond Road, Bangalore. (Appellant) (Respondent) Pan No. Aajcs3585J Assessment Year: 2014-15

transferred outside India before it reaches the / premise of the buyer in India. Payments were made through irrevocable letter of credit / and the buyer SI group Ltd is an independent and unrelated party and purchased the equipment from the appellant company on its own account. The purchase order was placed on a principle to principle basis. 21. In view