PR. COMMISSIONER OF INCOME TAX-7 vs. SMR AUTOMOTIVE SYSTEMS INDIA LTD.

condonation of delay of 54 days in filing the appeal] 2. This appeal concerns Assessment Year (AY) 2014-15. 3. Broadly, the only issue which arises for consideration is as to whether the Income Tax Appellate Tribunal [in short, “Tribunal] was correct in holding that the Specified Domestic Transactions (SDTs) did not attract the regime of transfer pricing, in view

LOUIS DREYFUS COMPANY INDIA PVT LTD,GURGAON vs. DCIT CIRCLE-2(1), NEW DELHI

In the result, the Appeal of the Assessee is dismissed

Bench: Shri Anil Chaturvedi & Shri Yogesh Kumar U.S.

delay in filing the appeal is condoned. 4. Brief facts of the case are that, the assessee filed return declaring loss of Rs. 64,17,81,731/- which has been processed by CPC. Later, the case of the assessee was selected for scrutiny under CASS. Draft order u/s 144C of the Act was passed on 21/12/2019 by assessing the income

DCM SHRIRAM LTD,NEW DELHI vs. ACIT, CIRCLE-7(1), NEW DELHI

92C (2) of the act.\n33. Further in case of the assessee for assessment year 2015 – 16 ,\nexternal corporate of purchase price of power from SEB is used as a\ncomparable discarding the Indian energy exchange rate by the learned CIT –\nA, and the same order has not been challenged before the higher forum, it\nbecomes final. This shows that

DCIT, NEW DELHI vs. DCM SHRIRAM LTD, NEW DELHI

92C (2) of the act.\n\n33. Further in case of the assessee for assessment year 2015 – 16 ,\nexternal corporate of purchase price of power from SEB is used as a\ncomparable discarding the Indian energy exchange rate by the learned CIT –\nA, and the same order has not been challenged before the higher forum, it\nbecomes final. This shows

DCM SHRIIRAM LIMITED,NEW DELHI vs. NEAC, NEW DELHI

92C (2) of the act.\n\n33. Further in case of the assessee for assessment year 2015 – 16 ,\nexternal corporate of purchase price of power from SEB is used as a\ncomparable discarding the Indian energy exchange rate by the learned CIT –\nA, and the same order has not been challenged before the higher forum, it\nbecomes final. This shows

DCM SHRIRAM LIMITED,DELHI vs. ASSESSMENT UNIT, DELHI

92C (2) of the act.\n33. Further in case of the assessee for assessment year 2015 – 16 ,\nexternal corporate of purchase price of power from SEB is used as a\ncomparable discarding the Indian energy exchange rate by the learned CIT –\nA, and the same order has not been challenged before the higher forum, it\nbecomes final. This shows that