(Now known as Sony India Limited)

capital, transportation, level of the market, i.e. retail or wholesale and so forth. The Rules and the analytical steps. 71. Sub-Sections (1) and (2) to Section 92C are applicable to the assessed, as well as the Assessing Officer invoking power under Sub-Section (3) to Section 92C of the Act. As noted above, sub-section (2) to Section

LM WIND POWER AS ,DENMARK vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE INTERNATIONAL TAX 2(2)(1), DELHI

In the result, ground raised by the assessee is allowed

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.Lm Wind Power As, Vs, Acit, Circle Juptervej 6, 6000 Kolding, International Tax 2(2)(1), Denmark – 999999. Delhi (Pan :Aabcl8590Q) (Appellant) (Respondent) Assessee By : Shri Ajay Vohra, Sr. Advocate Shri Aditya Vohra, Advocate Shri Arpitgoyal, Ca Revenue By : Shri Saroj Kumar Dubey, Cit Dr Date Of Hearing : 27.08.2025 Date Of Order : 21.11.2025 Order Per S. Rifaur Rahman: 1. This Appealpreferred By The Assessee Is Directed Against The Assessment Order Dated 27.01.2025 Passed By The Acit, Circle Int. Tax 2(2)(1), Delhi Under Section 143(3) R.W.S. 144C(13) Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2020-21 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act Raising Following Grounds Of Appeal :- “1. That On The Facts & Circumstances Of The Case & In Law, The Assessment Order Dated 29.07.2024 Passed Under Section 143(3) Read With Section 144C(13) Of The Income-Tax Act, 1961 (He Act") For Assessment Year 2020-21 Assessing The Total Income Of The Assessee At Rs.81,14, 14,893 Is Bad In Law, Void- Ab-Initio & Therefore, Liable To Be Quashed And/ Or Set Aside.

gains of business or profession” in accordance with the provisions of this Act.” (emphasis supplied) 44. He submitted that the action of the assessing officer in invoking the provisions of section 44DA of the Act to tax royalty income under the head ‘PGBP’ is erroneous, contrary to the facts emanating in the present case and statutory provisions and therefore, deserves

TATA NYK SHIPPING PTE. LTD. ,SINGAPORE vs. CIT INTERNATIONAL TAXATION-3, NEW DELHI

In the result, the appeal is allowed

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kediaassessment Year: 2016-17 M/S. Tata Nyk Shipping Pte. Vs. Commissioner Of Income Tax, Ltd., International Taxation-3, 6, Shenton Way, #18-08B, New Delhi Oue Downtown 2, Singapore Pan :Aadct9945P (Appellant) (Respondent)

Capital Partners (Singapore) VI FDI Three Pte. Ltd. Vs. ACIT in WP(C) No.2562/2022, judgment dated 30.01.2023 18 AY: 2016-17 10. Proceeding further, learned counsel submitted, the assessee is a tax resident of Singapore since its incorporation in 2007 and has been filing its tax returns in Singapore. He submitted, the tax returns filed by the assessee have been

RANBAXY LABORATORIES LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, we direct the AO to reduce the book profit u/s 115JB of the Act by the amount of reversal of the provision of Rs

Bench: Sh. I. C.Sudhir Judicialmember & Sh. Prashant Maharishia.Y.: - 2008-09 Ranbaxy Laboratories Ltd. Vs Acit 12Th Floor, Devika Tower, Range -15 6, Nehru Place New Delhi New Delhi Pan No. Aaacr0127N (Appellant) (Respondent)

capital gain on sale of land. It has also claimed deduction u/s 80 G and 80 IB & 80 IC of the Income tax Act 03. Assesse filed its return of income 29.09.2008 declaringtotal income of Rs.1583214228/- according to the normal computation and declared book profit of Rs.7623353938/- u/s 115JB of the Income tax Act. Assesse filed audit report in form

ACIT, INTERNATIONAL TAXATION, CIRCLE 3(1)(2), NEW DELHI vs. SABRE DECISION TECHNOLOGIES INTERNATIONAL LLC, USA

In the result, the appeal of the revenue is dismissed

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

92E. A reasonable guidance however, may be drawn from this definition for other sections in the Act in respect of a fixed place PE. The above definition suggests that a fixed place of business is required for a permanent establishment to exist. The AO in his order does not indicate as to how a fixed place PE exists

SABRE DECISION TECHNOLOGIES INTERNATIONAL LLC,NEW DELHI vs. ACIT, INTERNATIONAL TAXATION, CIRCLE 3(1)(2), NEW DELHI

In the result, the appeal of the revenue is dismissed

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

92E. A reasonable guidance however, may be drawn from this definition for other sections in the Act in respect of a fixed place PE. The above definition suggests that a fixed place of business is required for a permanent establishment to exist. The AO in his order does not indicate as to how a fixed place PE exists

SH. EVALUESERVE.COM PRIVATE LTD.,NEW DELHI vs. ITO, NEW DELHI

In the result ground No. 8 of the appeal of the assessee is dismissed

Bench: Shri I. C. Sudhir & Shri Prashant Maharishievalueserve.Com Private Vs. Ito, Ltd, Ward-11(2), 701, Guru Apartments, New Delhi Sector-14, Rohni, New Delhi Pan: Aaace8014F (Appellant) (Respondent)

gains of business and deduction under section 10 A shall be granted only from the balance income under this head. Therefore against the returned income of Rs. nil. The total income of the assessee was computed at Rs. 162535780/–. 10. The assessee preferred objections before the Ld. Dispute Resolution Panel who issued direction dated 28/07/2010 rejected all the contention

DABUR INVEST CORP,NEW DELHI vs. PRCIT-16, NEW DELHI

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

Bench: Shri N.K. Billaiya & Ms. Suchitra Kamble[A.Y 2013-14] & [A.Y 2014-15]

gains on alienation of shares by the foreign investor, interest income and income of any other nature shall be examined by the field formation in accordance with the provisions of Income – tax Act, 1961 and DTAA applicable to the facts of the case. e. Claim of any tax relief under the Income Tax act or the relevant DTAA will

DABUR INVEST CORP,NEW DELHI vs. PRCIT-16, NEW DELHI

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

Bench: Shri N.K. Billaiya & Ms. Suchitra Kamble[A.Y 2013-14] & [A.Y 2014-15]

gains on alienation of shares by the foreign investor, interest income and income of any other nature shall be examined by the field formation in accordance with the provisions of Income – tax Act, 1961 and DTAA applicable to the facts of the case. e. Claim of any tax relief under the Income Tax act or the relevant DTAA will

PERFETTI VAN MELLE INDIA PVT. LTD.,GURGAON vs. ACIT, CIRCLE-3(1), GURGAON

In the result, the additional ground raised by the assessee is allowed

Bench: The Income Tax Appellate Tribunal, Delhi Bench “I-2”, New Delhi

gain competitive advantage. TV advertisements/commercials and video clips in local cable networks and advertisements in local radio networks are produced in local languages to make a difference in the minds of the customer. The Company also gives print ads in newspapers and magazines on regular basis. The marketing team at Perfetti India decides the mix to be used for promotional

SAMSUNG INDIA ELECTRONICS PVT. LTD.,GURGAON vs. JCIT, NEW DELHI

Bench: Shri Amit Shukla & Shri Prashant Maharishi

gain at the expense of the Indian entity. 19. He submitted that Samsung is a globally well-known name in consumer goods industry and the strength of the brand enhances the sale of consumer goods by it in India, while competing with other domestic and global brands operating in the Indian market. It is the assessee, an Indian Company

SAMSUNG INDIA ELECTRONICS PVT. LTD.,GURGAON vs. ACIT, NEW DELHI

Bench: Shri Amit Shukla & Shri Prashant Maharishi

gain at the expense of the Indian entity. 19. He submitted that Samsung is a globally well-known name in consumer goods industry and the strength of the brand enhances the sale of consumer goods by it in India, while competing with other domestic and global brands operating in the Indian market. It is the assessee, an Indian Company

SANSUNG INDIA ELECTRONICS PVT. LTD.,GURGAON vs. ADDL. CIT, SPECIAL RANGE- 8 , NEW DELHI

Bench: Shri Amit Shukla & Shri Prashant Maharishi

gain at the expense of the Indian entity. 19. He submitted that Samsung is a globally well-known name in consumer goods industry and the strength of the brand enhances the sale of consumer goods by it in India, while competing with other domestic and global brands operating in the Indian market. It is the assessee, an Indian Company

ACIT, NEW DELHI vs. M/S SAMSUNG INDIA ELECTRONICS LTD.,, GURGAON

Bench: Shri Amit Shukla & Shri Prashant Maharishi

gain at the expense of the Indian entity. 19. He submitted that Samsung is a globally well-known name in consumer goods industry and the strength of the brand enhances the sale of consumer goods by it in India, while competing with other domestic and global brands operating in the Indian market. It is the assessee, an Indian Company

SAMSUNG INDIA ELECTRONICS PVT. LTD.,GURGAON vs. ADDL. CIT, NEW DELHI

Bench: Shri Amit Shukla & Shri Prashant Maharishi

gain at the expense of the Indian entity. 19. He submitted that Samsung is a globally well-known name in consumer goods industry and the strength of the brand enhances the sale of consumer goods by it in India, while competing with other domestic and global brands operating in the Indian market. It is the assessee, an Indian Company

SAMSUNG INDIA ELECTRONICS PVT. LTD.,GURGAON vs. ADDL. CIT, NEW DELHI

Bench: Shri Amit Shukla & Shri Prashant Maharishi

gain at the expense of the Indian entity. 19. He submitted that Samsung is a globally well-known name in consumer goods industry and the strength of the brand enhances the sale of consumer goods by it in India, while competing with other domestic and global brands operating in the Indian market. It is the assessee, an Indian Company

SAMSUNG INDIA ELECTRONICS PVT. LTD.,,GURGAON vs. ADDL. CIT, NEW DELHI

Bench: Shri Amit Shukla & Shri Prashant Maharishi

gain at the expense of the Indian entity. 19. He submitted that Samsung is a globally well-known name in consumer goods industry and the strength of the brand enhances the sale of consumer goods by it in India, while competing with other domestic and global brands operating in the Indian market. It is the assessee, an Indian Company

SAMSUNG INDIA ELECTRONICS PVT. LTD.,GURGAON vs. ADDL. CIT, NEW DELHI

Bench: Shri Amit Shukla & Shri Prashant Maharishi

gain at the expense of the Indian entity. 19. He submitted that Samsung is a globally well-known name in consumer goods industry and the strength of the brand enhances the sale of consumer goods by it in India, while competing with other domestic and global brands operating in the Indian market. It is the assessee, an Indian Company

SAMSUNG INDIA ELECTRONICS PVT. LTD.,GURGAON vs. DCIT CIRCLE-22(2), NEW DELHI

The appeal of the taxpayer is allowed for statistical purposes

Bench: Shri Kuldip Singh

gain as non-operating in nature for the purpose of computation of margins of the Appellant as well as of the comparables. 24. That on the facts and circumstances of the case and in law, the Ld. DRP/AO/TPO have erred in denying working capital adjustment under Rule10B(1)(e) for the purpose of determination of ALP to account