THE PR. COMMISSIONER OF INCOME TAX -6 vs. MARUTI SUZUKI INDIA LTD.

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

disallowance of deduction claimed under section 10B of the Act.  Said final assessment order was accompanied by notice of demand issued under section 156 and notice issued under section 274 read with section 271(1)(c) of the Act for initiating penalty proceedings. objections before the DRP, even though the Respondent was mandated by law to first forward draft assessment

THE PR. COMMISSIONER OF INCOME TAX -6 vs. MICROSOFT INDIA ( R & D) PVT. LTD.

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

disallowance of deduction claimed under section 10B of the Act.  Said final assessment order was accompanied by notice of demand issued under section 156 and notice issued under section 274 read with section 271(1)(c) of the Act for initiating penalty proceedings. objections before the DRP, even though the Respondent was mandated by law to first forward draft assessment

DEFSYS SOLUTIONS PVT. LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE-15, NEW DELHI

In the result the appeal of the assessee in ITA No

Bench: Shri N.K. Billaiya & Ms Astha Chandra

disallowed u/s 36(1)(va) r.w.s 43B of the Act. 5.2 Alternatively, the Ld. AO has erred in appreciating the fact and the law that the expenses incurred was wholly and exclusively for the purpose of business and should be allowed under section 37(1) of the Act. 6. That the Ld. AO has erred in making adjustment

FRESENIUS KABI ONCOLOGY LTD,NEW DELHI vs. ITO, WARD-9(3), NEW DELHI

In the result appeal of the assessee is allowed

Bench: Shri Prakash Chand Yadav & Shri Manish Agarwalfresenius Kabi Oncology Ltd. Income Tax Officer, B-310, Som Dutt Chamber, Ward-9(3), Bhikaji Cama Place, Vs. New Delhi. New Delhi-110066. Pan-Aabcd7720L (Appellant) (Respondent)

1. That on facts and circumstances of the case and in law, the order dated 02.12.2019 passed by the AO ("AO") under section 143(3) read with section 144C of the Income-tax Act, 1961 ("the Act") for assessment year 2015-16 is bad in law and void ab initio. 2. That on facts and circumstances of the case

DEFSYS SOLUTIONS P.LTD,NEW DELHI vs. ACIT, CENTRAL CIRCLE-15, NEW DELHI

In the result the appeal of the assessee in ITA No

Bench: Shri N.K. Billaiya & Ms Astha Chandra

1) of the Act, and therefore, the subsequent order passed by the Hon'ble DRP-1 u/s 144C (5) of the Act dated 16.03.2023, as well as the impugned order passed by the Ld, AO u/s 143(3) read with section 144C(13) of the Act dated 27.04.20203, are illegal and void. 2.2 The Hon'ble DRP has also erred

ARIBA INDIA PRIVATE LIMITED,DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, DELHI

In the result, appeal of the assessee is allowed

Bench: SHRI YOGESH KUMAR U.S (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

144C(13). 2. That on the facts and circumstances of the case and in law, the AO has erred in assessing the total income of the Appellant at IN 3,72,72,181 by making an Ariba India Pvt.Ltd. vs. ACIT addition amounting to INR 2,45,25,401 as against the returned income amounting to INR 1

CEVA FREIGHT INDIA PVT. LTD.,GURGAON vs. DCIT, NEW DELHI

Bench: Shri N. K. Saini & Ms Suchitra Kambleceva Freight India Pvt. Ltd. Vs Dcit (Now Merged With Ceva Logistics Circle-1(1), Gurgaon India Private Limited W.E.F. April, 5Th Floor, Hsiidc Building, 1, 2016 Vide Order Dated Vanijya Nikunj, Udyog November 9, 2017 Of National Vihar, Phase-V Company Law Tribunal) Gurgaon Sewa Tower, Plot No. 19, Sectdor- 18, 2Nd Floor, Block, C, Maruti Industrial Complex, Udyog Vihar Gurgaon Aaacc2674H (Respondent) (Appellant) Ceva Freight India Pvt. Ltd. Vs Dcit Sewa Tower, Plot No. 19, Sectdor- Circle-1(1), 18, 5Th Floor, Hsiidc Building, 2Nd Floor, Block, C, Maruti Vanijya Nikunj, Udyog Industrial Complex, Udyog Vihar Vihar, Phase-V Gurgaon Aaacc2674H Gurgaon (Appellant) (Respondent) Ceva Freight India Pvt. Ltd. Vs Acit Formerly Known As Egl Eagle Circle 1(1) Global Logistic (India) Pvt. Ltd. Gurgaon 1St Floor, Tower C, Dlf Building No. 10 Dlf Phase-Ii, Dlf Cyber (Respondent) City, Gurgaon Aaacc2674H (Appellant) Vs Dcit Formerly Known As Egl Eagle Circle 11(1) Global Logistic (India) Pvt. Ltd. New Delhi 1St Floor, Tower C, Dlf Building No. 10 Dlf Phase-Ii, Dlf Cyber (Respondent) City, Gurgaon Aaacc2674H (Appellant) Ceva Freight India Pvt. Ltd. Vs Dcit 1St Floor, Tower C, Dlf Building Circle 1(1) No. 10, Gurgaon Dlf Phase-Ii, Dlf Cyber City, Gurgaon Aaacc2674H (Respondent) (Appellant)

disallowance of Rs. 1,92,585 under Section 14A of the Act read with Rule 8D of the Rules. ITA No. 6135/Del/2016 A.Y. 2012-13 1. Pricing Adjustment - Rs. 29,29,71,236 That the Hon'ble Dispute Resolution Panel, New Delhi ("the DRP") has erred both in law and on facts by summarily rejecting the Appellant's objections

M/S CEVA FREIGHT (INDIA) PVT. LTD.,,GURGAON vs. ACIT, GURGAON

Bench: Shri N. K. Saini & Ms Suchitra Kambleceva Freight India Pvt. Ltd. Vs Dcit (Now Merged With Ceva Logistics Circle-1(1), Gurgaon India Private Limited W.E.F. April, 5Th Floor, Hsiidc Building, 1, 2016 Vide Order Dated Vanijya Nikunj, Udyog November 9, 2017 Of National Vihar, Phase-V Company Law Tribunal) Gurgaon Sewa Tower, Plot No. 19, Sectdor- 18, 2Nd Floor, Block, C, Maruti Industrial Complex, Udyog Vihar Gurgaon Aaacc2674H (Respondent) (Appellant) Ceva Freight India Pvt. Ltd. Vs Dcit Sewa Tower, Plot No. 19, Sectdor- Circle-1(1), 18, 5Th Floor, Hsiidc Building, 2Nd Floor, Block, C, Maruti Vanijya Nikunj, Udyog Industrial Complex, Udyog Vihar Vihar, Phase-V Gurgaon Aaacc2674H Gurgaon (Appellant) (Respondent) Ceva Freight India Pvt. Ltd. Vs Acit Formerly Known As Egl Eagle Circle 1(1) Global Logistic (India) Pvt. Ltd. Gurgaon 1St Floor, Tower C, Dlf Building No. 10 Dlf Phase-Ii, Dlf Cyber (Respondent) City, Gurgaon Aaacc2674H (Appellant) Vs Dcit Formerly Known As Egl Eagle Circle 11(1) Global Logistic (India) Pvt. Ltd. New Delhi 1St Floor, Tower C, Dlf Building No. 10 Dlf Phase-Ii, Dlf Cyber (Respondent) City, Gurgaon Aaacc2674H (Appellant) Ceva Freight India Pvt. Ltd. Vs Dcit 1St Floor, Tower C, Dlf Building Circle 1(1) No. 10, Gurgaon Dlf Phase-Ii, Dlf Cyber City, Gurgaon Aaacc2674H (Respondent) (Appellant)

disallowance of Rs. 1,92,585 under Section 14A of the Act read with Rule 8D of the Rules. ITA No. 6135/Del/2016 A.Y. 2012-13 1. Pricing Adjustment - Rs. 29,29,71,236 That the Hon'ble Dispute Resolution Panel, New Delhi ("the DRP") has erred both in law and on facts by summarily rejecting the Appellant's objections

M/S. CEVA FREIGHT (INDIA) PRIVATE LIMITED,GURGAON vs. DCIT, NEW DELHI

Bench: Shri N. K. Saini & Ms Suchitra Kambleceva Freight India Pvt. Ltd. Vs Dcit (Now Merged With Ceva Logistics Circle-1(1), Gurgaon India Private Limited W.E.F. April, 5Th Floor, Hsiidc Building, 1, 2016 Vide Order Dated Vanijya Nikunj, Udyog November 9, 2017 Of National Vihar, Phase-V Company Law Tribunal) Gurgaon Sewa Tower, Plot No. 19, Sectdor- 18, 2Nd Floor, Block, C, Maruti Industrial Complex, Udyog Vihar Gurgaon Aaacc2674H (Respondent) (Appellant) Ceva Freight India Pvt. Ltd. Vs Dcit Sewa Tower, Plot No. 19, Sectdor- Circle-1(1), 18, 5Th Floor, Hsiidc Building, 2Nd Floor, Block, C, Maruti Vanijya Nikunj, Udyog Industrial Complex, Udyog Vihar Vihar, Phase-V Gurgaon Aaacc2674H Gurgaon (Appellant) (Respondent) Ceva Freight India Pvt. Ltd. Vs Acit Formerly Known As Egl Eagle Circle 1(1) Global Logistic (India) Pvt. Ltd. Gurgaon 1St Floor, Tower C, Dlf Building No. 10 Dlf Phase-Ii, Dlf Cyber (Respondent) City, Gurgaon Aaacc2674H (Appellant) Vs Dcit Formerly Known As Egl Eagle Circle 11(1) Global Logistic (India) Pvt. Ltd. New Delhi 1St Floor, Tower C, Dlf Building No. 10 Dlf Phase-Ii, Dlf Cyber (Respondent) City, Gurgaon Aaacc2674H (Appellant) Ceva Freight India Pvt. Ltd. Vs Dcit 1St Floor, Tower C, Dlf Building Circle 1(1) No. 10, Gurgaon Dlf Phase-Ii, Dlf Cyber City, Gurgaon Aaacc2674H (Respondent) (Appellant)

disallowance of Rs. 1,92,585 under Section 14A of the Act read with Rule 8D of the Rules. ITA No. 6135/Del/2016 A.Y. 2012-13 1. Pricing Adjustment - Rs. 29,29,71,236 That the Hon'ble Dispute Resolution Panel, New Delhi ("the DRP") has erred both in law and on facts by summarily rejecting the Appellant's objections

CEVA FREIGHT (INDIA) PVT. LTD.,GURGAON vs. DCIT, GURGAON

Bench: Shri N. K. Saini & Ms Suchitra Kambleceva Freight India Pvt. Ltd. Vs Dcit (Now Merged With Ceva Logistics Circle-1(1), Gurgaon India Private Limited W.E.F. April, 5Th Floor, Hsiidc Building, 1, 2016 Vide Order Dated Vanijya Nikunj, Udyog November 9, 2017 Of National Vihar, Phase-V Company Law Tribunal) Gurgaon Sewa Tower, Plot No. 19, Sectdor- 18, 2Nd Floor, Block, C, Maruti Industrial Complex, Udyog Vihar Gurgaon Aaacc2674H (Respondent) (Appellant) Ceva Freight India Pvt. Ltd. Vs Dcit Sewa Tower, Plot No. 19, Sectdor- Circle-1(1), 18, 5Th Floor, Hsiidc Building, 2Nd Floor, Block, C, Maruti Vanijya Nikunj, Udyog Industrial Complex, Udyog Vihar Vihar, Phase-V Gurgaon Aaacc2674H Gurgaon (Appellant) (Respondent) Ceva Freight India Pvt. Ltd. Vs Acit Formerly Known As Egl Eagle Circle 1(1) Global Logistic (India) Pvt. Ltd. Gurgaon 1St Floor, Tower C, Dlf Building No. 10 Dlf Phase-Ii, Dlf Cyber (Respondent) City, Gurgaon Aaacc2674H (Appellant) Vs Dcit Formerly Known As Egl Eagle Circle 11(1) Global Logistic (India) Pvt. Ltd. New Delhi 1St Floor, Tower C, Dlf Building No. 10 Dlf Phase-Ii, Dlf Cyber (Respondent) City, Gurgaon Aaacc2674H (Appellant) Ceva Freight India Pvt. Ltd. Vs Dcit 1St Floor, Tower C, Dlf Building Circle 1(1) No. 10, Gurgaon Dlf Phase-Ii, Dlf Cyber City, Gurgaon Aaacc2674H (Respondent) (Appellant)

disallowance of Rs. 1,92,585 under Section 14A of the Act read with Rule 8D of the Rules. ITA No. 6135/Del/2016 A.Y. 2012-13 1. Pricing Adjustment - Rs. 29,29,71,236 That the Hon'ble Dispute Resolution Panel, New Delhi ("the DRP") has erred both in law and on facts by summarily rejecting the Appellant's objections

CEVA FREIGHT (INDIA) PVT. LTD.,GURGAON vs. DCIT, GURGAON

Bench: Shri N. K. Saini & Ms Suchitra Kambleceva Freight India Pvt. Ltd. Vs Dcit (Now Merged With Ceva Logistics Circle-1(1), Gurgaon India Private Limited W.E.F. April, 5Th Floor, Hsiidc Building, 1, 2016 Vide Order Dated Vanijya Nikunj, Udyog November 9, 2017 Of National Vihar, Phase-V Company Law Tribunal) Gurgaon Sewa Tower, Plot No. 19, Sectdor- 18, 2Nd Floor, Block, C, Maruti Industrial Complex, Udyog Vihar Gurgaon Aaacc2674H (Respondent) (Appellant) Ceva Freight India Pvt. Ltd. Vs Dcit Sewa Tower, Plot No. 19, Sectdor- Circle-1(1), 18, 5Th Floor, Hsiidc Building, 2Nd Floor, Block, C, Maruti Vanijya Nikunj, Udyog Industrial Complex, Udyog Vihar Vihar, Phase-V Gurgaon Aaacc2674H Gurgaon (Appellant) (Respondent) Ceva Freight India Pvt. Ltd. Vs Acit Formerly Known As Egl Eagle Circle 1(1) Global Logistic (India) Pvt. Ltd. Gurgaon 1St Floor, Tower C, Dlf Building No. 10 Dlf Phase-Ii, Dlf Cyber (Respondent) City, Gurgaon Aaacc2674H (Appellant) Vs Dcit Formerly Known As Egl Eagle Circle 11(1) Global Logistic (India) Pvt. Ltd. New Delhi 1St Floor, Tower C, Dlf Building No. 10 Dlf Phase-Ii, Dlf Cyber (Respondent) City, Gurgaon Aaacc2674H (Appellant) Ceva Freight India Pvt. Ltd. Vs Dcit 1St Floor, Tower C, Dlf Building Circle 1(1) No. 10, Gurgaon Dlf Phase-Ii, Dlf Cyber City, Gurgaon Aaacc2674H (Respondent) (Appellant)

disallowance of Rs. 1,92,585 under Section 14A of the Act read with Rule 8D of the Rules. ITA No. 6135/Del/2016 A.Y. 2012-13 1. Pricing Adjustment - Rs. 29,29,71,236 That the Hon'ble Dispute Resolution Panel, New Delhi ("the DRP") has erred both in law and on facts by summarily rejecting the Appellant's objections

NOKIA INDIA SALES P.LTD,NEW DELHI vs. ADDL.CIT, SPECIAL RANGE-6, , NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Sh. Amit Shukladr. B. R. R. Kumar(Through Video Conferencing) Ita No. 7244/Del/2017 : Asstt. Year : 2012-13 Nokia India Sales Pvt. Ltd., Vs Addl. Cit, 807, New Delhi House, Special Range-6, Barakhamba Road, New Delhi New Delhi-110001 (Appellant) (Respondent) Pan No. Aaccn9141L Assessee By : Sh. Nageshwar Rao, Adv. Revenue By : Sh. Surenderpal, Cit Dr Date Of Hearing: 29.07.2021 Date Of Pronouncement: 25.10.2021

144C(13) of the Income Tax Act, 1961. 2. Following grounds have been raised by the revenue: “1. That on the facts and circumstances of the case and in law, the Ld. AO has grossly erred in determining the taxable income of the Appellant for the subject assessment year at Rs. 323,10,98,940/-, as against the returned income

MICROSOFT CORPORATION (INDIA) PRIVATE LIMITED,NEW DELHI vs. DCIT, CIRCLE-16(1), NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh & Shri Yogesh Kumar Usmicrosoft Corporation (India) Vs. Dcit, Pvt. Ltd, Circle-16(1), 807, New Delhi House, New Delhi Barakhamba Road, New Delhi (Appellant) (Respondent) Pan: Aaacm5586C Assessee By : Shri Nageswar Rao & Parth, Adv Revenue By: Shri Rajesh Kumar, Cit(Dr) Date Of Hearing 22/02/2024 Date Of Pronouncement 28/02/2024

disallowance have been incorporated and such other functions as may be required for the purposes of review and the term "review unit", wherever used in this section, shall refer to an Assessing Officer having powers so assigned by the Board. (4) The assessment unit, verification unit, technical unit and the review unit shall have the following authorities, namely:— (i) Additional

L.S CABLE INDIA PVT LTD ,REWARI vs. DCIT, CIRCLE13(1), NEW DELHI

In the result, appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2018-19] L S Cable India Pvt.Ltd., Vs Dcit, Plot No.28-31, Sector-5, Cirlce-13(1), Phase-Ii, Hsiidc Gc Bawal, New Delhi Rewari, Haryana-23501. Pan-Aabcl3621Q Appellant Respondent Appellant By Shri Gaurav Garg, Ca Respondent By Shri S.K.Jhadav, Cit Dr Date Of Hearing 01.04.2025 Date Of Pronouncement 29.05.2025

disallowance/ additions and in initiating penalty proceedings under section 271(1)(c) of the Act. The Appellant craves leave to add, alter, modify or delete such other objections before or during the course of hearing before the Hon'ble Income Tax Appellate Tribunal (ITAT'), so as to enable the Hon'ble ITAT to decide on the grounds raised

GEODIS OVERSEAS PVT. LTD.,GURGAON vs. DCIT, NEW DELHI

The appeal of the assessee is allowed

Bench: Shri N. K. Billaiya & Ms Suchitra Kamble

section 144C(1 1) of the Act. 3.10 That on facts and circumstances of the case and in law, the directions are bad in law and void ab-initio as the DRP has erred in observing / directing that the management support and IT charges amounting to INR 90,936,248 are alternatively disallowable

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 filed by the assessee in ITA No

Bench: Shri N.K. Billaiya & Shri Kuldip Singh[Assessment Year: 2015-16]

1) Network Systems India Pvt Ltd New Delhi. 14th Floor, Tower B, Building No. 5 DLF Cyber City, New Delhi. PAN : AABCC 3425 B [Appellant] [Respondent] Date of Hearing : 24.09.2020 Date of Pronouncement : 28.09.2020 Assessee by : Shri Ravi Sharma, Adv Shri Rishab Malhotra, Adv Revenue by : Shri Sukesh Kumar Jain, CIT-DR ORDER PER N.K. BILLAIYA, ACCOUNTANT MEMBER, With this

VEDANTA LTD (SUCCESSOR TO CAIRN INDIA LTD),GURGAON vs. ACIT, CIRCLE-26(1), NEW DELHI

Bench: Hon’Ble, Shri N.K. Saini & Shri Kuldip Singh

section 144C of the 2 Income-tax Act, 1961 (for short ‘the Act’) qua the assessment year 2013-14 on the grounds inter alia that :- “1. That on the facts and circumstances of the case & in law, the Ld. Assessing Officer (AO) erred in assessing the total income and adjusted book profit of the Appellant at Rs.906

M/S. GLOBERIAN INDIA PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

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

disallowance of Rs.1,14,36,265/- on account of depreciation on computers. 3. The Learned DCIT erred in fact and in law in making an addition of Rs.4,12,04,919/- being a difference in Arms length Price.” 2. Briefly stated the facts necessary for adjudication of the controversy at hand are : in compliance to the directions issued by ITAT