EXL SERVICE.COM (INDIA) PVT. LTD.,NEW DELHI vs. DCIT (LTU), NEW DELHI

In the result, the appeal by the assessee as well as ofthe department are partly allowed for statistical purposes

Bench: Sh. N. K. Saini, Am & Sh. Kuldip Singh, Jm Ita No. 302/Del/2015 : Asstt. Year : 2010-11 Exl Service.Com (India) Pvt. Ltd., Vs Deputy Commissioner Of Income 414, 4Th Floor, Dlf Jasola, Tax, Large Tax Payer Unit, Tower-B, Plot No. 10 & 11, Dda New Delhi District Centre, Jasola, New Delhi-110044 (Appellant) (Respondent) Ita No. 615/Del/2015 : Asstt. Year : 2010-11 Deputy Commissioner Of Income Vs Exl Service.Com (India) Pvt. Ltd., 414, 4Th Floor, Dlf Jasola, Tower- Tax, Circle-1 (Ltu), New Delhi-110017 B, Plot No. 10 & 11, Dda District Centre, Jasola, New Delhi-110044 (Appellant) (Respondent) Pan No. Aaace5174C Assessee By : Sh. Ajay Vohra, Adv. Sh. Abhishek Agarwal, Adv. Revenue By : Sh. Piyush Jain, Cit Dr Date Of Hearing : 07.10.2017 Date Of Pronouncement : 03.01.2017 Order Per N. K. Saini, Am:

TP. The assessee in that case provided depreciation on assets under SLM at the rates higher than those provided in Schedule XIV, whereas the comparables provided for depreciation as per Income-tax Rules on written (supra). 5.18. The sum and substance of the above cases is that neither any adjustment can be made for a simplicitor higher/lower amount of depreciation

ECOENERGY INSIGHTS LTD ( FORMERLY KNOWN AS CHUBB ALBA CONTROL SYSTEMS P.LTD),NEW DELHI vs. DCIT, CIRCLE-4(2), NEW DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaecoenergy Insights Ltd., Vs. Dcit, (Formerly Known As Chubb Alba Control Circle 4 (2), Systems P. Ltd.), New Delhi. Ground Floor, 18, Netaji Subhash Marg, Daryaganj, New Delhi – 110 002. (Pan :Aaaca0031C) (Appellant) (Respondent) Assessee By : Shri Nageshwar Rao, Advocate Shri Parth, Advocate Shri Pratik Rath, Advocate Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 12.08.2025 Date Of Order : 10.11.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Assessment Order Dated 25.07.2022Passed By The Assessment Unit, Income Tax Department Under Section 147 Read With Section 144C(13) R.W.S. 144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Ay 2018-19 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act.

TP proceedings. Even in the remand report, the TPO has rightly intimated no worthwhile evidence has been furbished on any count.” 9. Aggrieved with the above order, assessee is in appeal before us raising following grounds of appeal:- “Ecoenergy insights Limited (formerly Chubb Alba Control System Private Limited) (hereinafter referred to as 'Ecoenergy Insights' or Appellant') craves leave to prefer

INDUCTIS INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeal of the assessee stands allowed in

Bench: Shri Pramod Kumar & Shri Sudhanshu Srivastavaasstt. Year: 2012-13

TP. Similarly for assessment year 2014-15, the Ld. DRP, vide its order dated 6.4.2018, directed the TPO to verify the claim of the assessee and re-compute the margins. The Ld. DRP has also noted in its directions for assessment year 2014-15 that the adjustment with respect to depreciation had also been upheld by the ITAT in assessee

VEDANTA LIMITED,NEW DELHI vs. ACIT, CIRCLE-26(2), NEW DELHI

Bench: Shri Anil Chaturvedi & Shri Kuldip Singh

Method accommodation expenses 4 Parent company overheads 415346005 5 Share of manpower general and 3975481665 administrative cost 6 Indirect charges 3705186 7 Sale of inventory and consumables 5089707 8 Transfer of inventory 4912809 Specific Domestic Transactions S.No. Nature of Transaction Amount in (Rs.) 1 Director’s remuneration 73306921 2 Director sitting fee 4700000 3 Payment of Commission 30000000 3 Transfer

M/S. G4S SECURITY SERVICES (INDIA) PVT. LTD.,GURGAON vs. ACIT, NEW DELHI

In the result, appeal filed by the assessee stands allowed for statistical purposes and the appeal filed by the Revenue stands dismissed

Bench: Shri N. K. Saini & Smt. Beena A. Pillai

TP study to determine the ALP. Ld. A.R. submitted that the assessee, while calculating operating expenses for computation of margin, had excluded certain extra ordinary expenses pertaining to prior period expenses, excess lease rent debited to P & L account due to change in the method of accounting, excess provision for bad debts due to change in management policy, excess depreciation

M/S BERGEN ENGINES INDIA PVT. LTD.,,NEW DELHI vs. ACIT, NEW DELHI

Appeal of the assessee is partly allowed for statistical purpose

Bench: Shri R. K. Panda & Ms Suchitra Kamble(Through Video Conferencing) Bergen Engines India Pvt. Ltd. Vs Acit 2Nd Floor, 52-B, Okhla Circle-4(2) Industrial Estate, New Delhi Phase-3, Okhla New Delhi Aaecb7223M (Appellant) (Respondent)

depreciation is an exceptional and non-operating item which required to be treated as such for making comparison of business segments. 7. The Ld. TPO as well as the DRP and consequently the AO have grossly erred in law and on facts in aggregating the trading and service segments for benchmarking transaction of purchase of traded goods which are functionally

YUTAKA AUTOPARTS INDIA PVT. LTD.,DELHI vs. DCIT, CIRCLE- 27(1), NEW DELHI

In the result appeal of the Revenue in ITA No

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Method in order to provide for excessive depreciation in the case Appellant vis-a-vis the comparable companies. 6. In law and on facts and circumstances of the case the appellant in the interest of justice, may be allowed to adduce additional evidence as may be necessary in support of the grounds raised hereinabove after following due procedures laid down

ACIT, CIRCLE- 27(2), NEW DELHI vs. YUTAKA AUTOPARTS INDIA PVT. LTD., DELHI

In the result appeal of the Revenue in ITA No

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Method in order to provide for excessive depreciation in the case Appellant vis-a-vis the comparable companies. 6. In law and on facts and circumstances of the case the appellant in the interest of justice, may be allowed to adduce additional evidence as may be necessary in support of the grounds raised hereinabove after following due procedures laid down

YUTAKA AUTOPARTS INDIA PVT. LTD.,DELHI vs. ITO, NEW DELHI

In the result appeal of the Revenue in ITA No

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Method in order to provide for excessive depreciation in the case Appellant vis-a-vis the comparable companies. 6. In law and on facts and circumstances of the case the appellant in the interest of justice, may be allowed to adduce additional evidence as may be necessary in support of the grounds raised hereinabove after following due procedures laid down

SONY INDIA PVT. LTD.,NEW DELHI vs. NATIOANAL E- ASSESMENT CENTRE, NEW DELHI

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

Bench: Shri Chandra Mohan Garg & Shri N.K. Billaiya

TP adjustment in respect of outstanding receivables. 40. Briefly stated, the facts of the case are that the assessee strongly contended that all receivables and payables being closely linked to respective main transactions, have been bench marked using combined transaction approach and working capital adjustment for which the assessee filed invoice-wise details for export of slow moving goods including

YUTAKA AUTOPARTS INDIA PVT. LTD.,DELHI vs. ITO, NEW DELHI

Bench: Shri R.K. Panda & Shri Kuldip Singh

method for providing depreciation in its books of account and for this 21 ITA No.1807/Del./2015 reason, high depreciation was charged in the initial year of operation and quantum of depreciation get reduced gradually. So, the taxpayer in its TP

PANASONIC INDIA PRIVATE LTD.,GURGAON vs. NEAC, NEW DELHI

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

Bench: Shri C. N. Prasad & Shri M. Balaganeshpanasonic India Pvt. Ltd, Vs. Neac, 12Th Floor, Ambience New Delhi Corporate Office, Tower-2, Ambience Island, Gurgaon (Appellant) (Respondent) Pan: Aadcp9391B

TP documentation. The Ld. TPO and the Hon‟ble Panel, while rejecting the RPM as the most appropriate method, erred in making flawed observations and not appreciating the established judicial precedents that support the applicability of RPM in the Company‟s case. In this regard, the observations made by the Ld. TPO in its order and the Appellant‟s rebuttals

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 study. Whatever comparables they have taken earlier they were for altogether different purpose. Here, there is no complete analysis. Therefore, they have to do complete analysis as to what are the filters applied, which are the comparables rejected/accepted and how many comparables finally selected. He accordingly submitted that the segmental RPM cannot be accepted unless fresh analysis has been

ROXTEC INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result appeal of the assessee is dismissed

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishiroxtec India Pvt. Ltd, Vs. Acit, 308, Hemkunt Chambers, Central Circle-21(2), 89, Nehru Place, New Delhi New Delhi Pan: Aadcr1329K (Appellant) (Respondent)

TP Study . It is apparent that in Resale Price Method if there is no substantial addition, should be used as the most appropriate method. However at page number 86 of the paper book assessee shows that it earns the gross profit of 35%, at page number 90 of the paper book assessee submits that its gross profit ratio

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

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