FUJITSU INDIA PVT. LTD.,NEW DELHI vs. ACIT, CIRCLE- 9(2), NEW DELHI

Bench: Shri Chandra Poojari & Shri Kuldip Singh

TP") documentation. 4. That on the facts and circumstances of the case and in law, the Ld. AO/ TPO/ Hon'ble DRP grossly erred in enhancing the income of the Appellant by INR 58,724,008 on account of rejecting Resale Price Method CRPM') as the Most Appropriate method and substituting the same with Transactional Net Margin Method (TNMM

TOWERS WATSON INDIA LTD.,GURGAON vs. ACIT, CIRCLE- 4(1), GURGAON

In the result, the appeal filed by the assessee is partly allowed

TP documentation and selecting Transactional Net Margin Method (“TNMM”) as the most appropriate method to determine the arm’s length price (“ALP”) of the impugned transaction without giving any plausible reasoning thereto. 3. The learned TPO/DRP have erred in disregarding internal TNMM proposed by the Appellant during the course of assessment without citing any cogent reasoning, and thereafter applying external

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

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

Bench: Shri R.K. Panda & Ms Suchitra Kambleassessment Year: 2004-05 Dcit, Vs. Exxon Mobil Lubricants P. Ltd., Circle-11(1), Ernst & Young Tower, New Delhi. B-26, Qutab Institutional Area, New Delhi. Pan Aabce0207H (Appellant) (Respondent) Assessee By : Shri S.D. Kapila, Advocate Shri R.R. Maurya, Advocate Revenue By : Shri H.K. Choudhary, Cit- Dr Order Per R.K. Panda, Am:

TP report itself has mentioned that CUP was rejected as the most appropriate method, therefore, CUP method cannot be applied. So far as trading segment is concerned, it is his submission that here also there is no complete analysis of data regarding the nature of filters to be applied and list of final comparables. It is his submission that segmental

CANON INDIA PVT. LTD.,GURGAON vs. DCIT, NEW DELHI

Appeal is dismissed

Bench: Shri R. K. Panda & Ms Suchitra Kamble

TP regulations in place in India, as a method for benchmarking the AMP expenditure incurred by the Appellant without correctly applying any of the methods in the manner prescribed under Rule 10B of the Rules. Without prejudice to the above grounds that the AMP expenditure incurred is not amenable to Chapter-X, the Appellant craves to raise following grounds

CANON INDIA PVT. LTD.,GURGAON vs. DCIT, NEW DELHI

Appeal is dismissed

Bench: Shri R. K. Panda & Ms Suchitra Kamble

TP regulations in place in India, as a method for benchmarking the AMP expenditure incurred by the Appellant without correctly applying any of the methods in the manner prescribed under Rule 10B of the Rules. Without prejudice to the above grounds that the AMP expenditure incurred is not amenable to Chapter-X, the Appellant craves to raise following grounds

DCIT, NEW DELHI vs. M/S. CANON INDIA PVT. LTD., GURGAON

Appeal is dismissed

Bench: Shri R. K. Panda & Ms Suchitra Kamble

TP regulations in place in India, as a method for benchmarking the AMP expenditure incurred by the Appellant without correctly applying any of the methods in the manner prescribed under Rule 10B of the Rules. Without prejudice to the above grounds that the AMP expenditure incurred is not amenable to Chapter-X, the Appellant craves to raise following grounds

DCIT, NEW DELHI vs. M/S. CANON INDIA PVT. LTD., GURGAON

Appeal is dismissed

Bench: Shri R. K. Panda & Ms Suchitra Kamble

TP regulations in place in India, as a method for benchmarking the AMP expenditure incurred by the Appellant without correctly applying any of the methods in the manner prescribed under Rule 10B of the Rules. Without prejudice to the above grounds that the AMP expenditure incurred is not amenable to Chapter-X, the Appellant craves to raise following grounds

M/S. LUMAX INDUSTRIES LTD.,NEW DELHI vs. JCIT, NEW DELHI

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

Bench: Shri R. K. Panda & Shri Kuldip Singhassessment Year : 2010-11 Lumax Industries Ltd., Jcit, Range- 4, B-85/86, Mayapuri Industrial New Delhi. Vs. Area, Phase-1, New Delhi. Pan : Aaacl1126D (Appellant) (Respondent)

TP study, the royalty transaction was analyzed by him separately under CUP method. According to him, the Act does not preclude the TPO to apply appropriate method for each 4 class of transactions like payments for intangible in the form of royalty and also apply TNMM at the enterprise level. 5. The TPO also did not accept the CUP used

SEAGRAM MANUFACTURING (P) LTD vs. ADDL CIT RANGE-8,

In the result, assessee’s appeals are partly allowed for statistical

Bench: Shri S.V. Mehrotra : & Shri Sudhanshu Srivastava :

TP method to test the overall profitability of assessee’s service function. The assessee was taken as the tested party on the ground that it was bearing less risk as compared to the AEs. The PLI for the TNM method analysis was taken as net profit to total expenses (or cost) ratio, termed as NCP in the T.P. report

SEAGRAM MANUFACTURING (P) LTD vs. ADDL CIT RANGE-8,

In the result, assessee’s appeals are partly allowed for statistical

Bench: Shri S.V. Mehrotra : & Shri Sudhanshu Srivastava :

TP method to test the overall profitability of assessee’s service function. The assessee was taken as the tested party on the ground that it was bearing less risk as compared to the AEs. The PLI for the TNM method analysis was taken as net profit to total expenses (or cost) ratio, termed as NCP in the T.P. report

DCIT CIRCLE 8 (1) vs. SEAGRAM MANUFACTURING (P) LTD,

In the result, assessee’s appeals are partly allowed for statistical

Bench: Shri S.V. Mehrotra : & Shri Sudhanshu Srivastava :

TP method to test the overall profitability of assessee’s service function. The assessee was taken as the tested party on the ground that it was bearing less risk as compared to the AEs. The PLI for the TNM method analysis was taken as net profit to total expenses (or cost) ratio, termed as NCP in the T.P. report

DCIT CIRCLE 8 (1) vs. SEAGRAM MANUFACTURING (P) LTD,

In the result, assessee’s appeals are partly allowed for statistical

Bench: Shri S.V. Mehrotra : & Shri Sudhanshu Srivastava :

TP method to test the overall profitability of assessee’s service function. The assessee was taken as the tested party on the ground that it was bearing less risk as compared to the AEs. The PLI for the TNM method analysis was taken as net profit to total expenses (or cost) ratio, termed as NCP in the T.P. report

GENPACT SERVICES LLC,GURGAON vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE - INT TAX 1(3)(1), DELHI

In the result, appeal of the assessee is partly allowed

Bench: Shri Prakash Chand Yadav\Nand\Nshri Brajesh Kumar Singh\N\Nita No. 4477/Del/2024\N[Assessment Year: 2020-21]\N\N| Genpact Services Llc,\Nplot 22A & B, Sector 18,\Nudyog Vihar,\Ngurgaon, Haryana-122002\Npan-Aaccg3353P\Nappellant\N|\Nassistant Commissioner Of Income\Ntax, Circle-International Tax-1(3)(1),\Nvs Delhi-110002\Nrespondent\N\N| Appellant By\Nshri Vishal Kalra, Adv.,\Nms. Reema Malik, Adv.& Ms.\Nsnigdha Gautam, Adv.\Nrespondent By\Nshri S.K. Jadhav, Cit Dr\N\Ndate Of Hearing\N30.07.2025\Ndate Of Pronouncement\N31.07.2025\N\Norder\N\Nper Brajesh Kumar Singh, Am,\Nthis Appeal By The Assessee Is Directed Against The Order Of The\Nassessing Officer Dated 29.07.2024 Passed U/S 143(3) R.W.S.144C(13) Of\Nthe Income Tax Act, 1961 (Hereinafter ‘The Act') In Pursuance To The\Ndirections Of Dispute Resolution Panel Dated 25.06.2024 Pertaining To\N Assessment Year 2020-21.\N2. The Relevant Facts Are That The Assessee Is An Indian Branch Office Of\Ngenpact Llc, A Usa Company. The Assessee Is A Service Provider\Nrendering Off-Shore Support Services Akin To Bpo Services, Including\Ncollections/Analytics Call Centre Services & Other Back-Office Support\Nservices To Its Aes. The Assessee Is Responsible For Rendering The\Ndesignated Bpo / Collections Services From Its Facility / Infrastructure In\Nindia. As For Assessment Year 2020-21, The Assessee Filed Its Return Of\Nincome (Roi') Declaring An Income Of Inr 20,57,10,540/- On 07.01.2021.\Nduring The Course Of Scrutiny, The Assessing Officer Made A Reference U/S\N92Ca Of The Act To The Transfer Pricing Officer (Tpo') To Determine The\Narm'S Length Price (‘Alp') In Respect Of International Transaction Entered\Ninto By The Assessee.\N2.

method for\nmaking adjustment qua these expenses. However, we further note that\nthere is no material change in the basis and the conclusion arrived both\nby the TPO and the Assessing Officer in this case and the identical\namount of disallowance of Rs.9,32,12,889/- has been determined by the\nTPO by changing the cost allocation methodology from headcount

LG ELECTRONICS INDIA PRIVATE LIMITED,MATHURA ROAD, NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

TP adjustment in respect of international transaction of payment of design and development charges. We, accordingly, direct the Assessing Officer/TPO to delete the same. Ground No. 9 is accordingly, allowed.‖ 9.2 Respectfully following the same, grounds raised by the assessee in this regard are hereby allowed. 10. The next issue to be decided in this appeal is challenging the disallowance

LG ELECTRONICS INDIA PVT. LTD.,NEW DELHI vs. DCIT, CIRCLE-15(2), NEW DELHI

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

TP adjustment in respect of international transaction of payment of design and development charges. We, accordingly, direct the Assessing Officer/TPO to delete the same. Ground No. 9 is accordingly, allowed.‖ 9.2 Respectfully following the same, grounds raised by the assessee in this regard are hereby allowed. 10. The next issue to be decided in this appeal is challenging the disallowance

DCIT, NOIDA vs. M/S. L.G. ELECTRONICS INDIA PVT. LTD., GREATER NOIDA

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

TP adjustment in respect of international transaction of payment of design and development charges. We, accordingly, direct the Assessing Officer/TPO to delete the same. Ground No. 9 is accordingly, allowed.‖ 9.2 Respectfully following the same, grounds raised by the assessee in this regard are hereby allowed. 10. The next issue to be decided in this appeal is challenging the disallowance

M/S LG ELECTRONICS INDIA PVT. LTD.,,NEW DELHI vs. DCIT, NOIDA

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

TP adjustment in respect of international transaction of payment of design and development charges. We, accordingly, direct the Assessing Officer/TPO to delete the same. Ground No. 9 is accordingly, allowed.‖ 9.2 Respectfully following the same, grounds raised by the assessee in this regard are hereby allowed. 10. The next issue to be decided in this appeal is challenging the disallowance

DCIT, CIRCLE-13(1), NEW DELHI vs. LG ELECTRONICS INDIA PVT. LTD., DELHI

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

TP adjustment in respect of international transaction of payment of design and development charges. We, accordingly, direct the Assessing Officer/TPO to delete the same. Ground No. 9 is accordingly, allowed.‖ 9.2 Respectfully following the same, grounds raised by the assessee in this regard are hereby allowed. 10. The next issue to be decided in this appeal is challenging the disallowance