M/S DABUR INDIA LTD.,,DELHI vs. ACIT, NEW DELHI

In the result appeal of the assessee is partly allowed for statistical purposes and that of the department is dismissed

Bench: Sh. N. K. Saini, Am & Sh. Sudhanshu Srivastava, Jm Ita No. 3257/Del/2013 : Asstt. Year : 2006-07 Dabur India Ltd., Vs Asstt. Commissioner Of Income 8/3, Asaf Ali Road, Tax, Central Circle-22, New Delhi New Delhi (Appellant) (Respondent) Pan No. Aaacd0474C

house property & other sources. The AO pointed out that the assessee was having following undertaking in the year under consideration: " Hajmola Unit, Baddi " Pudin Hara Unit, Baddi " Softgel Unit, Baddi " C.Prash Unit, Baddi " Amala extract/Honey Unit, Baddi " Glucose unit,Baddi " Shampoo unit " Tooth paste unit, Baddi " Honitus Unit, Baddi " Jammu unit ITA Nos. 3257 & 3492/Del/2013 19 Dabur India Ltd. " Uttranchal

LM WIND POWER AS ,DENMARK vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE INTERNATIONAL TAX 2(2)(1), DELHI

In the result, ground raised by the assessee is allowed

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.Lm Wind Power As, Vs, Acit, Circle Juptervej 6, 6000 Kolding, International Tax 2(2)(1), Denmark – 999999. Delhi (Pan :Aabcl8590Q) (Appellant) (Respondent) Assessee By : Shri Ajay Vohra, Sr. Advocate Shri Aditya Vohra, Advocate Shri Arpitgoyal, Ca Revenue By : Shri Saroj Kumar Dubey, Cit Dr Date Of Hearing : 27.08.2025 Date Of Order : 21.11.2025 Order Per S. Rifaur Rahman: 1. This Appealpreferred By The Assessee Is Directed Against The Assessment Order Dated 27.01.2025 Passed By The Acit, Circle Int. Tax 2(2)(1), Delhi Under Section 143(3) R.W.S. 144C(13) Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2020-21 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act Raising Following Grounds Of Appeal :- “1. That On The Facts & Circumstances Of The Case & In Law, The Assessment Order Dated 29.07.2024 Passed Under Section 143(3) Read With Section 144C(13) Of The Income-Tax Act, 1961 (He Act") For Assessment Year 2020-21 Assessing The Total Income Of The Assessee At Rs.81,14, 14,893 Is Bad In Law, Void- Ab-Initio & Therefore, Liable To Be Quashed And/ Or Set Aside.

92A of the Act. The international transaction is defined by Section 92B as to mean a transaction between two or more associated enterprises, either or both of whom are non- residents, in the nature of purchase, sale or lease of tangible or intangible property or provision of services etc. or any other transaction having a bearing on the profits, income

AMADEUS INDIA PVT. LTD.,NEW DELHI vs. ACIT, CIRCLE- 2(2), NEW DELHI

In the result, ITA NO. 7691/Del/2017 stands allowed

Bench: Shri N.S. Saini & Shri Sudhanshu Srivastava

House, Connaught Place, New Delhi PAN : AAACA0364L Appellant Respondent Assessee by : Sh. Tarundeep Singh, Adv. Revenue by : Shri Sanjay I.Bara, CIT-DR 2 Stay No. 475, 476/d/2018& ITA no. 1662/d/2016 (Amadeus India P. Ltd.) Date of Hearing 29.01.2019 Date of Pronouncement 27.02.2019 ORDER PER SUDHANSHU SRIVASTAVA, J.M. : These appeals have been filed challenging additions/ disallowances made by the Assessing Officer

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

In the result, ITA NO. 7691/Del/2017 stands allowed

Bench: Shri N.S. Saini & Shri Sudhanshu Srivastava

House, Connaught Place, New Delhi PAN : AAACA0364L Appellant Respondent Assessee by : Sh. Tarundeep Singh, Adv. Revenue by : Shri Sanjay I.Bara, CIT-DR 2 Stay No. 475, 476/d/2018& ITA no. 1662/d/2016 (Amadeus India P. Ltd.) Date of Hearing 29.01.2019 Date of Pronouncement 27.02.2019 ORDER PER SUDHANSHU SRIVASTAVA, J.M. : These appeals have been filed challenging additions/ disallowances made by the Assessing Officer

AMADEUS INDIA PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, ITA NO. 7691/Del/2017 stands allowed

Bench: Shri N.S. Saini & Shri Sudhanshu Srivastava

House, Connaught Place, New Delhi PAN : AAACA0364L Appellant Respondent Assessee by : Sh. Tarundeep Singh, Adv. Revenue by : Shri Sanjay I.Bara, CIT-DR 2 Stay No. 475, 476/d/2018& ITA no. 1662/d/2016 (Amadeus India P. Ltd.) Date of Hearing 29.01.2019 Date of Pronouncement 27.02.2019 ORDER PER SUDHANSHU SRIVASTAVA, J.M. : These appeals have been filed challenging additions/ disallowances made by the Assessing Officer

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

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

Bench: Shri S.V. Mehrotra & Shri Chandra Mohan Garg

House, Circle-2(1), 21, K.G. Marg, New Delhi. New Delhi. (PAN: AAACB0298A) (Appellant) (Respondent) Appellant by: S/Shri S.D. Kalipa, R.R.Maurya, Praveen Sharma, Sanjay Kumar, Advocates Respondent by : S/Shri Ravi Jain, CIT DR, Subhakant Sahoo, Sr. DR Date of last hearing: 12.10.2015 Date of pronouncement: 14.10.2015 O R D E R PER CHANDRAMOHAN GARG, J.M. This appeal by the assessee

SAMSUNG INDIA ELECTRONICS PVT. LTD.,GURGAON vs. ADDL. CIT, NEW DELHI

Bench: Shri Amit Shukla & Shri Prashant Maharishi

houses, advertising agencies, marketing bodies etc.) and cannot be treated as related party transactions merely because some incidental benefit is said to accrue to the AEs. 24. The Ld. Counsel also made a without prejudice argument regarding the quantum and composition of AMP expenditure taken by the TPO. The TPO while determining the value of international transaction

SAMSUNG INDIA ELECTRONICS PVT. LTD.,GURGAON vs. ADDL. CIT, NEW DELHI

Bench: Shri Amit Shukla & Shri Prashant Maharishi

houses, advertising agencies, marketing bodies etc.) and cannot be treated as related party transactions merely because some incidental benefit is said to accrue to the AEs. 24. The Ld. Counsel also made a without prejudice argument regarding the quantum and composition of AMP expenditure taken by the TPO. The TPO while determining the value of international transaction

SANSUNG INDIA ELECTRONICS PVT. LTD.,GURGAON vs. ADDL. CIT, SPECIAL RANGE- 8 , NEW DELHI

Bench: Shri Amit Shukla & Shri Prashant Maharishi

houses, advertising agencies, marketing bodies etc.) and cannot be treated as related party transactions merely because some incidental benefit is said to accrue to the AEs. 24. The Ld. Counsel also made a without prejudice argument regarding the quantum and composition of AMP expenditure taken by the TPO. The TPO while determining the value of international transaction

SAMSUNG INDIA ELECTRONICS PVT. LTD.,,GURGAON vs. ADDL. CIT, NEW DELHI

Bench: Shri Amit Shukla & Shri Prashant Maharishi

houses, advertising agencies, marketing bodies etc.) and cannot be treated as related party transactions merely because some incidental benefit is said to accrue to the AEs. 24. The Ld. Counsel also made a without prejudice argument regarding the quantum and composition of AMP expenditure taken by the TPO. The TPO while determining the value of international transaction

SAMSUNG INDIA ELECTRONICS PVT. LTD.,GURGAON vs. JCIT, NEW DELHI

Bench: Shri Amit Shukla & Shri Prashant Maharishi

houses, advertising agencies, marketing bodies etc.) and cannot be treated as related party transactions merely because some incidental benefit is said to accrue to the AEs. 24. The Ld. Counsel also made a without prejudice argument regarding the quantum and composition of AMP expenditure taken by the TPO. The TPO while determining the value of international transaction

SAMSUNG INDIA ELECTRONICS PVT. LTD.,GURGAON vs. ADDL. CIT, NEW DELHI

Bench: Shri Amit Shukla & Shri Prashant Maharishi

houses, advertising agencies, marketing bodies etc.) and cannot be treated as related party transactions merely because some incidental benefit is said to accrue to the AEs. 24. The Ld. Counsel also made a without prejudice argument regarding the quantum and composition of AMP expenditure taken by the TPO. The TPO while determining the value of international transaction

SAMSUNG INDIA ELECTRONICS PVT. LTD.,GURGAON vs. ACIT, NEW DELHI

Bench: Shri Amit Shukla & Shri Prashant Maharishi

houses, advertising agencies, marketing bodies etc.) and cannot be treated as related party transactions merely because some incidental benefit is said to accrue to the AEs. 24. The Ld. Counsel also made a without prejudice argument regarding the quantum and composition of AMP expenditure taken by the TPO. The TPO while determining the value of international transaction

ACIT, NEW DELHI vs. M/S SAMSUNG INDIA ELECTRONICS LTD.,, GURGAON

Bench: Shri Amit Shukla & Shri Prashant Maharishi

houses, advertising agencies, marketing bodies etc.) and cannot be treated as related party transactions merely because some incidental benefit is said to accrue to the AEs. 24. The Ld. Counsel also made a without prejudice argument regarding the quantum and composition of AMP expenditure taken by the TPO. The TPO while determining the value of international transaction

ACIT, NEW DELHI vs. M/S. EXPEDITORS INTERNATIONAL OF WASHINGTON,

In the result, the appeal of the revenue is dismissed

Bench: Ms. Sushma Chowladr. B. R. R. Kumar(E-Court Module) Ita No. 1740/Del/2015 : Asstt. Year : 2010-11 Asstt. Commissioner Of Income Vs M/S Expeditors International Of Washington, 1015, 3Rd Avenue, Tax, Circle-1(2)(2), International 12Th Floor, Seattle Washington Taxation, New Delhi (Appellant) (Respondent) Pan No. Aacce4315R Assessee By : Sh. Deepak Chopra, Adv. Revenue By : Sh. Satpal Gulati, Cit Dr Date Of Hearing: 25.08.2020 Date Of Pronouncement: 30.09.2020

Housing Agent (CHA) for import of goods at the custom station; iv. Warehousing of goods (if required) till the time the necessary customs -clearances are obtained; v. Transportation of goods to the ultimate consumer in USA; 19. In line with worldwide acceptable standards in the logistics industry and the group’s policy, the income from freight logistics operations represents gross

ACIT CIR, 31 (1) ROOM NO. 217, NEW DELHI vs. RNGS CONSORTIUM, NEW DELHI

In the result ITA No. 153/Del/2009 is dismissed

Bench: Shri Amit Shukla & Shri Prashant Maharishiasst Commissioner Of Income Vs. M/S. Rngs Consortium, Tax, 8, Aradhana Colony, Circle-31(1), Cr Building, Ip Sector-13, Rk Puram, New Estate, New Delhi Delhi (Appellant) (Respondent) Dcit, Vs. M/S. Expotec International Circle-11(1), Ltd, 8, Aradhana Colony, Rk New Delhi Puram, Sector-13, New Delhi (Appellant) (Respondent)

Housing & Land Development Trust: 161 ITR 524 (SC), wherein the assessee, was a limited company dealing in land and was maintaining its accounts on the mercantile system. By an order dated June 21, 1946, under rule 75A(1) of the Defence of India Rules read with section 19 of the Defence of India Act, 1939, certain plots of land measuring

HALDOR TOPSOE (I) PVT LTD,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal is partly allowed

Bench: Shri Bhavnesh Saini & Shri Anadee Nath Misshra

92A(2)(a) and (b) wherein a limit of less than 26% is fixed. Therefore, this Panel declines to interfere with the stand taken by the TPO in this regard. Rejecting comparables having different accounting year On the Comparables maintaining accounts in terms of period other than the financial year has been considered and DRP is of following view

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

In the result the appeal filed by the assessee stands allowed for statistical purposes

Bench: Shri N. K. Saini & Smt. Beena A. Pillaii.T.(Tp) No.166/Del.2013 (Assessment Year 2008-09) M/S. Showa India Pvt. Ltd., Vs. Dcit, Circle 8(1), 23-32, Sector 58, New Delhi Faridabd, Haryana-121002 Gir / Pan :Aabce5725G (Appellant) (Respondent)

92A of the Act. . 2.4. That on the facts of the case the Ld. AO has grossly erred in making an addition amounting to Rs.12,829,790/- twice, the same already being included in the aforesaid additions amounting to Rs.23,664,501/-. 3. That on the facts of the case the Ld. AO has grossly erred in making an addition

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)

houses, the main source of revenue is advertisement charges. The advertisers approach classified agents or accredited advertising agencies to advertise. The agents/agencies upon receipt of advertisement requirement procure the airtime from the media companies at a discount. Advertisers while making payment to accredited agencies duly deduct tax as required under law under section 194C of the Act on the amount