ACIT, NEW DELHI vs. M/S. HUMBOLDT WEDAG INDIA PVT. LTD., NEW DELHI

In the result ITA 3207/Del/2016 stands allowed

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

condone the delay. 3. Brief facts of the case are that the assessee is a wholly owned subsidiary of KHD Humboldt Wedag International GmbH (Humboldt Austria). The company is primarily engaged in designing, supplying of equipment, supervision of installation, erection and commissioning activities for the cement industry on a turn-key basis (non-civil). The return of income for assessment

HUMBOLDT WEDAG INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result ITA 3207/Del/2016 stands allowed

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

condone the delay. 3. Brief facts of the case are that the assessee is a wholly owned subsidiary of KHD Humboldt Wedag International GmbH (Humboldt Austria). The company is primarily engaged in designing, supplying of equipment, supervision of installation, erection and commissioning activities for the cement industry on a turn-key basis (non-civil). The return of income for assessment

HUMBOLDT WEDAG INDIA PVT. LTD.,DELHI vs. ACIT, NEW DELHI

In the result ITA 3207/Del/2016 stands allowed

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

condone the delay. 3. Brief facts of the case are that the assessee is a wholly owned subsidiary of KHD Humboldt Wedag International GmbH (Humboldt Austria). The company is primarily engaged in designing, supplying of equipment, supervision of installation, erection and commissioning activities for the cement industry on a turn-key basis (non-civil). The return of income for assessment

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

LOCKHEED MARTIN INDIA PVT. LTD.,NEW DELHI vs. ACIT, CIRCLE- 15(2), NEW DELHI

In the result of field of the assessee is partly allowed

Bench: Shri Prashant Maharishi & Shri K.N.Chary(Through Video Conferencing)

section 92C of the Act to determine the arm's length price. The ld TPO passed the order u/s 92CA (3) of the Act on 28.01.2016. The ld TPO determined the arm's length price of the international transaction related to “Provision of marketing support services” of Rs. 2,11,26,934/- and therefore the same was added

MAVENIR INDIA PVT. LTD. (EARLIER KNOWN AS COMVERSE NETWORK SYSTEM INDIA PVT. LTD.),GURGAON vs. DCIT, CIRCLE- 3(1), GURGOAN

In the result, the appeal is partly allowed

Bench: Shri Saktijit Dey & Shri Anadee Nath Misshrar Assessment Year: 2016-17

condone the delay of 25 days and admit the appeal for adjudication on merit. 5. The assessee has raised the following grounds: “1. On the facts and circumstances of the case, & in law the assessment order passed by the Additional / Joint / Deputy / Assistant Commissioner of Income Tax/ Income-tax Officer, National e-Assessment Centre (‘the 3 Ld. AO’) under Section

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

EGIS INTERNATIONAL S.A. ,NEW DELHI vs. ACIT, CIRCLE-INT. TAX 1(2)(2), NEW DELHI

In the result, the appeal of the assessee is treated as allowed for statistical purposes

Bench: Shri M. Balaganesh & Ms. Astha Chandraasstt. Year: 2016-17 Egis International S.A. Vs. Acit T-305, Tf, Circle-1Nt. Tax 1(2)(2) Tirupati Plaza, New Delhi. Sector-11 (Mlu), Pocket 4, Plot No. 11 Dwarka, New Delhi – 110 075. Pan Aabcb7760L (Appellant) (Respondent)

92C(3) of the Act are satisfied in the present case. While doing so, the Ld AO/ Ld TPO/ Ld CIT(A) grossly erred in not acknowledging that:  even after rejection of 2 comparable companies identified in the Transfer Pricing Report (viz. Anand Projects Limited and Wapcos Ltd.), the Comparable Set has 6 Companies and therefore, there was no requirement

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 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

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

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

M/S. NOKIA SOLUTIONS AND NETWORKS INDIA PVT. LTD.,GURGAON vs. DCIT, NEW DELHI

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastavaassessment Year: 2006-07 Nokia Solutions & Networks India Pvt. Ltd., Vs Dcit, (Formerly Known As Nokia Siemens Circle-18(2), Networks Pvt. Ltd.), 7Th Floor, Room No. 406, Building No. 9A, Dlf Cyber City, C.R. Building, Sector 25A, I.P. Estate, Gurgaon-122002 New Delhi. (Pan: Aaccn3871F) (Appellant) (Respondent) Appellant By: Shri Deepak Chopra, Adv. Respondent By: Shri T.M. Shiva Kumar, Cit Dr

92C of Act for purposes of computing the arm's length price under Section 92F of the Act. Corporate tax Grounds - 5. The learned AO has erred in law and in fact in holding the capital receipt of Rs. 10,84,21,198 being secured loan waived off in accordance with the notification issued by the Government of West Bengal

PRINCIPAL COMMISSIONER OF INCOME TAX, DELHI-1 vs. BORGWARNER EMISSIONS SYSTEMS INDIA PRIVATE LTD.

Appeal is allowed

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

delay of 310 days in re- filing the appeal is condoned. 2. The application is disposed of. ITA 750/2025 3. This appeal has been filed with the following prayers:- “1. Frame the substantial Questions of Law mentioned in Para 3 of the appeal; 2. Frame any other substantial Questions of Law which may arise from the Impugned Order dated