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. CIT-9, NEW DELHI vs. M/S TIMEX GROUP INDIA LTD. FIRST FLOOR, TOWER B,

Bench: HON'BLE MR. JUSTICE VIPIN SANGHI,HON'BLE MR. JUSTICE SANJEEV NARULA

delay is condoned. 4. The application stands disposed of in the aforesaid terms. ITA 795/2019 5. The Revenue has preferred the present appeal to assail the order dated 20.12.2018 passed by the learned Income Tax Appellate Tribunal (hereinafter referred to as ‘ITAT’) in ITA No. 845/Del/2016 and CO No. 95/Del/2016 in relation to the Assessment Year

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

ACIT, NEW DELHI vs. M/S. SPENTEX INDUSTRIES LTD., NEW DELHI

Bench: Shri Kuldip Singh & Shri Prashant Maharishi

Method (TNMM) as the value of the international transactions was at Rs.2,89,13,63,550/-. AO called upon the assessee to explain as to why the arm’s length price of transactions qua corporate guarantee be not determined. During the year under assessment, corporate guarantee has been given by the taxpayer to its AE in the following cases

ANSAL BUILDWELL LIMITED,NEW DELHI vs. ACIT, CIRCLE-2(2), NEW DELHI

In the result, the appeal of the assessee is partly allowed

Bench: Sh. Saktijit Dey & Sh. N. K. Billaiyaassessment Year: 2017-18 Ansal Buildwell Limited Vs. Acit 118, Uff, Prakash, Deep Circle-2 (2) Building, 7, Tolstoy Marg, New Delhi Connaught Place, New Delhi-110001 Pan No.Aaaca2845E (Appellant) (Respondent) Appellant By Sh. Satyajeet Goel, Advocate Respondent By Sh. Kanv Bali, Sr. Dr Date Of Hearing: 20/12/2023 Date Of Pronouncement: 22/12/2023 Order

delay is condoned. 5. Coming to the merits we find that during the year the assessee has earned dividend income of Rs.1615/- which was claimed as exempt u/s. 10 of the Act. The assessee suo-moto disallowed a sum of Rs.565962/- u/s. 14A of the Act. 6. However, invoking the rule 8D the AO computed the disallowance at Rs.11

DCIT, NEW DELHI vs. M/S. SONY MOBILE COMMUNICATIONS INTERNATIONAL AB, NEW DELHI

In the result, the appeal is partly allowed

Bench: : Shri S.K. Yadav & Shri L.P. Sahu

delay is condoned. 4. The first major issue raised by the assessee in his appeal is against the addition of Rs.6,23,15,808/- made by the AO on account of transfer pricing adjustment, which was reduced to Rs.5,57,09,134/- vide rectification order u/s. 154 dated 09.12.2014. 5. Briefly stated, the facts of the case are that

M/S. SONY MOBILE COMMUNICATIONS INTERNATIONAL AB (INDIA BRANCH OFFICE),NEW DELHI vs. DDIT, NEW DELHI

In the result, the appeal is partly allowed

Bench: : Shri S.K. Yadav & Shri L.P. Sahu

delay is condoned. 4. The first major issue raised by the assessee in his appeal is against the addition of Rs.6,23,15,808/- made by the AO on account of transfer pricing adjustment, which was reduced to Rs.5,57,09,134/- vide rectification order u/s. 154 dated 09.12.2014. 5. Briefly stated, the facts of the case are that

YOKOHAMA INDIA PRIVATE LIMITED,HARYANA vs. DCIT, CIRCLE-27(2), NEW DE

In the result, all the appeals of the assessee are partly allowed

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh[Assessment Year: 2016-17]

condone the delay for ITA number 856 and proceed to decide the appeal. 4. Brief facts as coming out from the orders of the authorities below are that during the year under consideration the assessee company was engaged in trading of tyres which it imports from it's holding company named M/s Yokohama Rubber Company limited Japan. We are taking

YOKOHAMA INDIA PRIVATE LIMITED,BAHADURGARH, JHAJJAR, HARYANA vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT, NATIONAL FACELESS ASSESSMENT CENTRE, ASSESSMENT UNIT, INCOME TAX DEPARTMENT, NATIONAL FACELESS ASSESSMENT CENTRE

In the result, all the appeals of the assessee are partly allowed

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh[Assessment Year: 2016-17]

condone the delay for ITA number 856 and proceed to decide the appeal. 4. Brief facts as coming out from the orders of the authorities below are that during the year under consideration the assessee company was engaged in trading of tyres which it imports from it's holding company named M/s Yokohama Rubber Company limited Japan. We are taking

YOKOHAMA INDIA PRIVATE LIMITED,JHAJJAR vs. DCIT, CIRCLE-25(1), DELHI

In the result, all the appeals of the assessee are partly allowed

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh[Assessment Year: 2016-17]

condone the delay for ITA number 856 and proceed to decide the appeal. 4. Brief facts as coming out from the orders of the authorities below are that during the year under consideration the assessee company was engaged in trading of tyres which it imports from it's holding company named M/s Yokohama Rubber Company limited Japan. We are taking

ACIT, CENTRAL CIRCLE- 16, NEW DELHI vs. YORK HOTELS PVT. LTD., NEW DELHI

In the result, all the appeals of the assessee are partly allowed

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh[Assessment Year: 2016-17]

condone the delay for ITA number 856 and proceed to decide the appeal. 4. Brief facts as coming out from the orders of the authorities below are that during the year under consideration the assessee company was engaged in trading of tyres which it imports from it's holding company named M/s Yokohama Rubber Company limited Japan. We are taking

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

BECHTEL INDIA PVT. LTD.,,NEW DELHI vs. ADDL.CIT,SPECIAL RANGE-2, NEW DELHI

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

Bench: Shri O.P. Kant & Ms. Suchitra Kamble

method for benchmarking the transaction of interest on receivables and using SBI prime lending rate, computed adjustment for interest on receivables amounting to ₹ 1,30,78,181/-. On the objections of the assessee, the Learned 15 ITA No.7234/Del./2017 DRP noted that in assessment year 2010-11, the Tribunal following the decision of the Tribunal in the case of Kusum

PR. COMMISSIONER OF INCOME TAX-2, vs. M/S. BELKIN INDIA PRIVATE LIMITED

Bench: Issuing Notice On This Application, We Deem It Appropriate To Examine The Appeal On Merits.

Method (TNMM), net profit margin established by the TP analysis is taken into account to arrive at the arm‟s length price qua international transactions. In case of MRUC being a not- for-profit organisation, profit making is not the motive rather it is operating in media research covering media sellers and buyers for some specific motive of the company

PRINCIPAL COMMISSIONER OF INCOME TAX-8 vs. ST MICROELECTRONICS PRIVATE LTD.

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE SANJEEV SACHDEVA

delay of 69 days in filing the appeal is condoned. ITA 913/2017 1. The question of law urged in this case is whether the deletion of 16 comparables originally proposed by the Transfer Pricing Officer ITA 913/2017 Page 2 of 5 (TPO) in the course of assessment for AY 2007-2008, in the ALP (Arms Length Price) determination, conducted

DCIT, NEW DELHI vs. M/S RAYBAN SUN OPTICS INDIA LTD.,, BHIWANI

Bench: Shri R.K. Panda & Shri Kuldip Singh(Through Video Conference)

delay of 38 days in filing the present appeal is hereby condoned. 5. This is second round of litigation as the issue concerning transfer pricing of Advertising, Marketing & Promotional (AMP) expenses was set aside to the file of AO for deciding afresh by the coordinate Bench of the Tribunal in ITA No.5282/Del/2011 vide order dated 09.08.2012 by determining following findings

RAYBAN OPTICS INDIA LTD.,,BHIWANI vs. DCIT, NEW DELHI

Bench: Shri R.K. Panda & Shri Kuldip Singh(Through Video Conference)

delay of 38 days in filing the present appeal is hereby condoned. 5. This is second round of litigation as the issue concerning transfer pricing of Advertising, Marketing & Promotional (AMP) expenses was set aside to the file of AO for deciding afresh by the coordinate Bench of the Tribunal in ITA No.5282/Del/2011 vide order dated 09.08.2012 by determining following findings

DCIT CIRCLE-4(2), NEW DELHI vs. BENETTON INDIA PRIVATE LIMITED., GURGAON

In the result, the appeal of the revenue is dismissed and appeal of the assessee is dismissed

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganeshdcit, Vs. Benetton India Pvt. Ltd, Circle-4(2), B-25, Gurgaon, Haryana New Delhi (Appellant) (Respondent) Pan: Aaacd1013F Benetton India Pvt. Ltd, Vs. Dcit, B-25, Gurgaon, Haryana Circle-4(2), New Delhi (Appellant) (Respondent) Pan: Aaacd1013F

condone the delay and admit the appeal of the revenue for adjudication. 3. The revenue has raised the following grounds of appeal before us:- “1. Whether on facts and circumstances of the case and in law, the Ld. CIT(A) was right in holding that the reimbursements of expenses are at arm's length and in deleting the adjustments made