M/S. NEW DELHI TELEVISION LTD.,NEW DELHI vs. ACIT, NEW DELHI

Bench: Shri H. S. Sidhu & Shri Prashant Maharishinew Delhi Television Ltd, Vs. Acit, 207, Okhla Industrial Estate, Phase- Circle-13(1), Iii, New Delhi New Delhi Pan: Aaacn0865D (Appellant) (Respondent) Acit, Vs. New Delhi Television Ltd, Circle-13(1), 207, Okhla Industrial Estate, New Delhi Phase-Iii, New Delhi Pan: Aaacn0865D (Appellant) (Respondent)

section 92C(2) of the Act. 5. That on facts and in law and in law the CIT(A) has erred in upholding the action of I AO in making a disallowance

DCIT, NEW DELHI vs. M/S. NEW DELHI TELEVISION LTD., NEW DELHI

Bench: Shri H. S. Sidhu & Shri Prashant Maharishinew Delhi Television Ltd, Vs. Acit, 207, Okhla Industrial Estate, Phase- Circle-13(1), Iii, New Delhi New Delhi Pan: Aaacn0865D (Appellant) (Respondent) Acit, Vs. New Delhi Television Ltd, Circle-13(1), 207, Okhla Industrial Estate, New Delhi Phase-Iii, New Delhi Pan: Aaacn0865D (Appellant) (Respondent)

section 92C(2) of the Act. 5. That on facts and in law and in law the CIT(A) has erred in upholding the action of I AO in making a disallowance

DCIT, NEW DELHI vs. M/S XANSA INDIA LTD., NOIDA

In the result appeal of the revenue is dismissed

Bench: Smt Diva Singh & Shri Prashant Maharishi

2) of the Act and disallowance of Rs. 2822882/- on account of legal and professional charges expenses holding that it is paid to various non residence and on which tax is not deducted at source therefore disallowable u/s 40a(i) of the Act. Some other minor disallowances were also made. DCIT V Xansa India Limited ITA No. 2283/Del/2011 (Assessment Year

(Now known as Sony India Limited)

Sections (1) and (2) to Section 92C are applicable to the assessed, as well as the Assessing Officer invoking power under Sub-Section (3) to Section 92C of the Act. As noted above, sub-section (2) to Section 92C stipulates that most appropriate method, out of the methods specified in sub-section (1) shall be applied to determine

HERO MOTOCORP LIMITED,NEW DELHI vs. JCIT, NEW DELHI

In the result appeal of the assessee in ITA No

Bench: Sh. I. C. Sudhir & Shri Prashant Maharishihero Motocorp Limited, Jcit, 34, Basant Lok, Vasant Range-1, New Delhi Vs. Vihar, New Delhi Pan: Aaach0812J (Appellant) (Respondent) Dcit, M/S. Hero Moto Corp. Circle-11(1), Ltd., 34, Community Vs. New Delhi Centre, Basant Lok, Vasant Vihar, New Delhi-110057 (Appellant) (Respondent) Dcit, M/S. Hero Moto Corp. Circle-11(1), Ltd., 34, Community

disallowed on the ground of the same being contingent in nature. He further submitted that similar provision for increase in prices as at the end of the year was accepted and allowed in Hero MotoCorp Limited Vs. JCIT & DCIT Vs. Hero MotoCorp Ltd. ITA Nos. 1545/Del/2015 and 2424/Del/2015 (AY 2010-11) ITA No. 1609/Del/2016 and 914/Del/2016 (AY 2011-12) Page

CIT vs. CUSHMAN AND WAKEFIELD INDIA PVT LTD

The appeal is partly allowed

2) the Board is empowered to prescribe the period for which the assessee must maintain the prescribed information and records. Pursuant thereto, the Board has stipulated that the prescribed information and documents be kept and maintained for a period of eight years from the end of the relevant assessment year - Rule 10D (5). Under section 92D (3), the Assessing Officer

MITSUI & CO INDIA PVT. LTD,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME-TAX, NEW DELHI

Appeals are partly allowed and

Bench: Shri S.V.Mehrotrashri Kuldip Singhmitsui & Co. India Pvt. Ltd., Vs. Dcit, Plot No. D-1, 4Th Floor, Salcon Ras Vilas, Circle 6 (1), District Centre Saket, New Delhi. New Delhi (Pan :Aadcm4488J) Mitsui & Co. India Pvt. Ltd., Vs. Dcit, Plot No. D-1, 4Th Floor, Salcon Ras Vilas, Circle 16(2), District Centre Saket, New Delhi New Delhi. (Pan :Aadcm4488J) (Appellant) (Respondent) Assessee By : Shri Ved Jain, Advocate, Sh. Ashu Goel, Ca & Shri Ashish, Ca Revenue By : Shri Amrendra Kumar, Cit, Dr Date Of Hearing : 27.01.2016 Date Of Pronouncement : 25.04.2016

92C (2); that TPO/DRP/AO has erred in disallowing an amount of Rs. 18,73,472/- u/s 14A of the Act and disallowing an amount of Rs. 1,111,510/- on account of prior period expenditure; that TPO/DRP/AO has also erred in disallowing an amount of Rs. 2,29,831/- by invoking the provision of section

M/S. MITSUI & CO. INDIA PVT LTD.,NEW DELHI vs. DCIT, NEW DELHI

Appeals are partly allowed and

Bench: Shri S.V.Mehrotrashri Kuldip Singhmitsui & Co. India Pvt. Ltd., Vs. Dcit, Plot No. D-1, 4Th Floor, Salcon Ras Vilas, Circle 6 (1), District Centre Saket, New Delhi. New Delhi (Pan :Aadcm4488J) Mitsui & Co. India Pvt. Ltd., Vs. Dcit, Plot No. D-1, 4Th Floor, Salcon Ras Vilas, Circle 16(2), District Centre Saket, New Delhi New Delhi. (Pan :Aadcm4488J) (Appellant) (Respondent) Assessee By : Shri Ved Jain, Advocate, Sh. Ashu Goel, Ca & Shri Ashish, Ca Revenue By : Shri Amrendra Kumar, Cit, Dr Date Of Hearing : 27.01.2016 Date Of Pronouncement : 25.04.2016

92C (2); that TPO/DRP/AO has erred in disallowing an amount of Rs. 18,73,472/- u/s 14A of the Act and disallowing an amount of Rs. 1,111,510/- on account of prior period expenditure; that TPO/DRP/AO has also erred in disallowing an amount of Rs. 2,29,831/- by invoking the provision of section

ADDL. CIT, SPECIAL RANGE- 03, NEW DELHI vs. DLF LTD., NEW DELHI

Bench: Shri Amit Shukla & Prashant Maharishi

2) and as such the recording satisfaction is sine qua non before proceeding to compute disallowance under 8D. On careful perusal of assessment order, we find that assessing officer has nowhere recorded its dissatisfaction I.T.As. No.5940 & 5941/DEL/2017 and CO No.5 & 6/DEL/2021 32 regarding suo moto disallowance made by the assessee and the entire discussion revolves around quantum of investment appearing

JINDAL STAINLESS LTD.,HISAR vs. DCIT, NEW DELHI

Accordingly, ground number 2 of the appeal of the learned AO for 2007 – 08 is dismissed

Bench: Smt Diva Singh & Shri Prashant Maharishi

2,646.335 115 432 6,367.050 15 304 HRAP Coil 4 444.740 111 401 3,666.023 9 430 Black Coil 8 436.020 55 2 1.240 1 J4 Black Coil 296 45,205.790 153 174 2,243.400 13 J4 HRAP Coil 32 2,202.630 69 69 605.482 9 J4 Plate 14 382.805 27 104 858.935 8 JSL AUS Black Coil

DCIT, NEW DELHI vs. M/S JSL LTD.,, HISAR

Accordingly, ground number 2 of the appeal of the learned AO for 2007 – 08 is dismissed

Bench: Smt Diva Singh & Shri Prashant Maharishi

2,646.335 115 432 6,367.050 15 304 HRAP Coil 4 444.740 111 401 3,666.023 9 430 Black Coil 8 436.020 55 2 1.240 1 J4 Black Coil 296 45,205.790 153 174 2,243.400 13 J4 HRAP Coil 32 2,202.630 69 69 605.482 9 J4 Plate 14 382.805 27 104 858.935 8 JSL AUS Black Coil

TRANSCEND MT SERVICES PVT. LTD.,NEW DELHI vs. ITO, NEW DELHI

Bench: Shri B.P. Jain & Shri Kuldip Singh

section 92C(2) the assessee was eligible for 5 per cent of adjustments. Since the amendment has been made effective from 1/10/2009 it is held that the assessee will be eligible for 5 per cent of adjustment while computing arms length price. The assessing officer is directed accordingly. So, in view of the matter, grounds no.1.1.7 and 1.1.8 are determined

TRANSCEND MT SERVICES PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

Bench: Shri B.P. Jain & Shri Kuldip Singh

section 92C(2) the assessee was eligible for 5 per cent of adjustments. Since the amendment has been made effective from 1/10/2009 it is held that the assessee will be eligible for 5 per cent of adjustment while computing arms length price. The assessing officer is directed accordingly. So, in view of the matter, grounds no.1.1.7 and 1.1.8 are determined

GE MONEY FINANCIAL SERVICES PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result ground, no

Bench: Shri A.T.Varkey & Shri Prashant Maharishi

2. Active Active Directory (AD) is a Microsoft Directory technology which provides various network services like Authentication, windows client management, DNS Software security, server maintenance, authentication of servers. HQ provides support & hosting for AD. AD is used by businesses globally and has about 130 Domain Controllers (Servers which host AD database). There are some Domain Controllers, software and supporting servers

GE MONEY FINANCIAL SERVICES PVT. LTD.,DELHI vs. DCIT, NEW DELHI

In the result ground, no

Bench: Shri A.T.Varkey & Shri Prashant Maharishi

2. Active Active Directory (AD) is a Microsoft Directory technology which provides various network services like Authentication, windows client management, DNS Software security, server maintenance, authentication of servers. HQ provides support & hosting for AD. AD is used by businesses globally and has about 130 Domain Controllers (Servers which host AD database). There are some Domain Controllers, software and supporting servers

DCIT CIRCLE-10(1), NEW DELHI vs. HTC INDIA PVT LTD, GURGAON

In the result, the appeal of the Revenue is dismissed

Bench: Sh. Kul Bharatdr. B. R. R. Kumar

2) provides that the most appropriate method referred to in sub-section (1) shall be applied for determining ALP in the manner as may be prescribed. Thus, it can be noticed that there are five methods specifically mentioned in addition to clause (f) of section 92C(1)which refers to 'such other method as may be prescribed by the Board

PR.COMMISSIONER OF INCOME TAX-2, vs. SINOSTEEL INDIA PVT. LTD.

Bench: HON'BLE MR. JUSTICE SANJIV KHANNA,HON'BLE MR. JUSTICE CHANDER SHEKHAR

2 of 11 comparable while applying the Comparable Uncontrolled Price (CUP) method. 3. Respondent-assessee was providing support and assistance to its holding company and associated enterprises in procuring and supplying metallurgical materials and related activities, for which the respondent-assessee was paid commission in related international transactions @ US$ 0.15 per DMT and US$ 0.33 per WMT. 4. During

ACIT, CIRCLE-18(2), NEW DELHI vs. NIIT TECHNOLOGIES LTD.,, NEW DELHI

Appeal is allowed for statistical

Bench: Shri S Rifaur Rahman & Ms. Madhumita Royita Nos.2889 & 2890/Del/2018 (Assessment Years: 2009-10 & 2010-11)

disallowance u/s 14A of the Act made while calculating Book Profit u/s 115JB of the Act by ignoring the fact that clause (f) of Explanation 1 to section 115JB(2) of the Act, introduced by Finance Act 2006 is applicable to the assessee for the year under consideration ? 5. The appellant craves leave for reserving the right to amend, modify

ACIT, CIRCLE-18(2), NEW DELHI vs. NIIT TECHNOLOGIES LTD.,, NEW DELHI

Appeal is allowed for statistical

Bench: Shri S Rifaur Rahman & Ms. Madhumita Royita Nos.2889 & 2890/Del/2018 (Assessment Years: 2009-10 & 2010-11)

disallowance u/s 14A of the Act made while calculating Book Profit u/s 115JB of the Act by ignoring the fact that clause (f) of Explanation 1 to section 115JB(2) of the Act, introduced by Finance Act 2006 is applicable to the assessee for the year under consideration ? 5. The appellant craves leave for reserving the right to amend, modify