DCIT, NEW DELHI vs. EICR (CYPRUS) LTD., NEW DELHI

In the result, the appeals of the Revenue in ITA Nos

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.

b) "eligible assessee" means,- i)any person in whose case the variation referred to in sub-section (1) arises as a consequence of the order of the Transfer Pricing Officer passed under sub-section (3) of section 92-CA; and(ii)any foreign company.]” CO Nos. 473 & 474/Del/2015 DCIT Vs. EICR (Cyprus) Ltd. 11. In the present cases

DCIT, NEW DELHI vs. NEWBURY HOLDING LTD., NEW DELHI

In the result, the appeals of the Revenue in ITA Nos

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.

b) "eligible assessee" means,- i)any person in whose case the variation referred to in sub-section (1) arises as a consequence of the order of the Transfer Pricing Officer passed under sub-section (3) of section 92-CA; and(ii)any foreign company.]” CO Nos. 349 & 350/Del/2015 DCIT Vs. Newbury Holding Ltd. 11. In the present cases

DCIT, NEW DELHI vs. NEWBURY HOLDING LTD., NEW DELHI

In the result, the appeals of the Revenue in ITA Nos

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.

b) "eligible assessee" means,- i)any person in whose case the variation referred to in sub-section (1) arises as a consequence of the order of the Transfer Pricing Officer passed under sub-section (3) of section 92-CA; and(ii)any foreign company.]” CO Nos. 349 & 350/Del/2015 DCIT Vs. Newbury Holding Ltd. 11. In the present cases

DCIT, NEW DELHI vs. GAINWAY HOLDINGS LTD., NEW DELHI

In the result, the appeal of the Revenue in ITA No

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.Dcit Gainway Holdings Ltd. Vs Central Circle-19, Room C/O. Sandeep Chilana, Advocate No. 362, Ara Centre, E-2, Chilana & Chilana Law Offices, Jhandewalan Extension, Advoate For The Respondent C- New Delhi 56, Lfg, Jangpura Extention, New Delhi-110014 Pan: Aafcg6056L Appellant Respondent

b) "eligible assessee" means,- i)any person in whose case the variation referred to in sub-section (1) arises as a consequence of the order of the Transfer Pricing Officer passed under sub-section (3) of section 92-CA; and(ii)any foreign company.]” 17. In the present case, the AO has not passed the draft assessment order byin compliance

DCIT, NEW DELHI vs. FOCUSOIL INC., NEW DELHI

In the result, the appeal of the Revenue in ITA No

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.Dcit Vs Focusoil Inc. Central Circle-19, Room C/O. Sandeep Chilana, Advocate No. 362, Ara Centre, E-2, Chilana & Chilana Law Offices, Jhandewalan Extension, Advoate For The Respondent C- New Delhi 56, Lfg, Jangpura Extention, New Delhi-110014 Pan: Aaccf3908K Appellant Respondent

b) "eligible assessee" means,- i)any person in whose case the variation referred to in sub-section (1) arises as a consequence of the order of the Transfer Pricing Officer passed under sub-section (3) of section 92-CA; and(ii)any foreign company.]” 17. In the present case, the AO has not passed the draft assessment order byin compliance

DCIT, NEW DELHI vs. GYNIA HOLDING LTD., NEW DELHI

In the result, the appeals of the Revenue in ITA Nos

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.

b) "eligible assessee" means,- i)any person in whose case the variation referred to in sub-section (1) arises as a consequence of the order of the Transfer Pricing Officer passed under sub-section (3) of section 92-CA; and(ii)any foreign company.]” 16. In the present cases, the AO has not passed the draft assessment order

DCIT, NEW DELHI vs. GYNIA HOLDING LTD., NEW DELHI

In the result, the appeals of the Revenue in ITA Nos

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.

b) "eligible assessee" means,- i)any person in whose case the variation referred to in sub-section (1) arises as a consequence of the order of the Transfer Pricing Officer passed under sub-section (3) of section 92-CA; and(ii)any foreign company.]” 16. In the present cases, the AO has not passed the draft assessment order

DCIT, NEW DELHI vs. GYNIA HOLDING LTD., NEW DELHI

In the result, the appeals of the Revenue in ITA Nos

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.

b) "eligible assessee" means,- i)any person in whose case the variation referred to in sub-section (1) arises as a consequence of the order of the Transfer Pricing Officer passed under sub-section (3) of section 92-CA; and(ii)any foreign company.]” 16. In the present cases, the AO has not passed the draft assessment order

DCIT, NEW DELHI vs. BENNETT WILLIAMSON ENGINEERS LTD., NEW DELHI

In the result, the appeals of the Revenue in ITA Nos

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.

b) "eligible assessee" means,- i)any person in whose case the variation referred to in sub-section (1) arises as a consequence of the order of the Transfer Pricing Officer passed under sub-section (3) of section 92-CA; and(ii)any foreign company.]” 16. In the present cases, the AO has not passed the draft assessment order

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

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

TDS. 10. It was brought to our notice that the assessee is an ‘eligible assessee’ for the purpose of Section 144C(15)(b

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

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

TDS. 10. It was brought to our notice that the assessee is an ‘eligible assessee’ for the purpose of Section 144C(15)(b

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

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

TDS. 10. It was brought to our notice that the assessee is an ‘eligible assessee’ for the purpose of Section 144C(15)(b

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

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

TDS. 10. It was brought to our notice that the assessee is an ‘eligible assessee’ for the purpose of Section 144C(15)(b

DCIT, NEW DELHI vs. M/S WICKWOOD DEVELOPMENT LTD.,, NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

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

TDS. 10. It was brought to our notice that the assessee is an ‘eligible assessee’ for the purpose of Section 144C(15)(b

DCIT, NEW DELHI vs. ISERVICES INVESTMENTS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

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

TDS. 10. It was brought to our notice that the assessee is an ‘eligible assessee’ for the purpose of Section 144C(15)(b

DCIT, NEW DELHI vs. EICR (CYPRUS) LTD., NEW DELHI

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.

b) "eligible assessee" means,- i)any person in whose case the variation referred to in sub-section (1) arises as a consequence of the order of the Transfer Pricing Officer passed under sub-section (3) of section 92-CA; and(ii)any foreign company.]” 11. In the present cases, the AO has not passed the draft assessment order in compliance

DCIT, NEW DELHI vs. BENNETT WILLIAMSON ENGINEERS LTD., NEW DELHI

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.

b) "eligible assessee" means,- i)any person in whose case the variation referred to in sub-section (1) arises as a consequence of the order of the Transfer Pricing Officer passed under sub-section (3) of section 92-CA; and(ii)any foreign company.]" 16. In the present cases, the AO has not passed the draft assessment order

BECHTEL LIMITED,LONDON vs. ACIT, CIRCLE INT. TAX 1(1)(2), NEW DELHI

In the result, appeal of the assessee is allowed

TDS of 10% was already deducted on the same and the tax liability was met. b. Secondly, the nature of services provided are engineering services. In the paper book for AY 2020-21, where the contracts have been filed, it is stated that the services provided are in the nature of engineering services to the end customer, Reliance Industries. Refer

BECHTEL LTD,LONDON vs. ACIT, CIRCLE 1(1)(2), INTERNATIONAL TAXATION, NEW DELHI

In the result, appeal of the assessee is allowed

TDS of 10% was already deducted on the same and the tax liability was met. b. Secondly, the nature of services provided are engineering services. In the paper book for AY 2020-21, where the contracts have been filed, it is stated that the services provided are in the nature of engineering services to the end customer, Reliance Industries. Refer