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

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.

2% of the value of each international transaction may be levied for failure to report international transaction in Form No.3CEB.In this regard, reference is made to section 92E which provides that parties, who have entered into an international transaction during the previous year, shall obtain a report from an accountant and furnish such report on or before the specified date

HERO MOTOCORP LTD.,NEW DELHI vs. DCIT, CIRCLE- 11(1), NEW DELHI

Appeal of the assessee is partly allowed for statistical purpose

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

Section 115JB of the Income Tax Act, 1961. In the present Assessment Year also the facts are similar and are squarely covered with the decision of the Tribunal for A.Ys. 2010-11, 2011-12, 2012-13 and 2013-14. Hence Ground Nos. 15 to 14.3 are allowed. 24. As regards Ground No. 16 to 16.2 is relating to Disallowance

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

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)

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

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

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

92A of the Act and consequently the order of the CIT (Appeals) upholding the chargeability of royalty from two AEs, as alleged by TPO, is arbitrary, unjust and bad in law. 2) That the CIT (Appeals) has erred on facts and under the law in upholding the jurisdiction of the TPO to determine "arms length price" in respect of alleged

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

92A of the Act and consequently the order of the CIT (Appeals) upholding the chargeability of royalty from two AEs, as alleged by TPO, is arbitrary, unjust and bad in law. 2) That the CIT (Appeals) has erred on facts and under the law in upholding the jurisdiction of the TPO to determine "arms length price" in respect of alleged

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

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

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

Bench: Shri Amit Shukla & Shri Prashant Maharishi

2 to 12) 14. Grounds 3.1 to 3.6 taken by the appellant in its appeal for AY 2005-06 are as below: GROUND NO. 3.1: The AO/CIT(A) has erred by not providing reasons for rejecting the analysis undertaken by the appellant for benchmarking the international transaction pertaining to reimbursement of advertisement expenses. GROUND

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

Bench: Shri Amit Shukla & Shri Prashant Maharishi

2 to 12) 14. Grounds 3.1 to 3.6 taken by the appellant in its appeal for AY 2005-06 are as below: GROUND NO. 3.1: The AO/CIT(A) has erred by not providing reasons for rejecting the analysis undertaken by the appellant for benchmarking the international transaction pertaining to reimbursement of advertisement expenses. GROUND

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

Bench: Shri Amit Shukla & Shri Prashant Maharishi

2 to 12) 14. Grounds 3.1 to 3.6 taken by the appellant in its appeal for AY 2005-06 are as below: GROUND NO. 3.1: The AO/CIT(A) has erred by not providing reasons for rejecting the analysis undertaken by the appellant for benchmarking the international transaction pertaining to reimbursement of advertisement expenses. GROUND

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

Bench: Shri Amit Shukla & Shri Prashant Maharishi

2 to 12) 14. Grounds 3.1 to 3.6 taken by the appellant in its appeal for AY 2005-06 are as below: GROUND NO. 3.1: The AO/CIT(A) has erred by not providing reasons for rejecting the analysis undertaken by the appellant for benchmarking the international transaction pertaining to reimbursement of advertisement expenses. GROUND

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

Bench: Shri Amit Shukla & Shri Prashant Maharishi

2 to 12) 14. Grounds 3.1 to 3.6 taken by the appellant in its appeal for AY 2005-06 are as below: GROUND NO. 3.1: The AO/CIT(A) has erred by not providing reasons for rejecting the analysis undertaken by the appellant for benchmarking the international transaction pertaining to reimbursement of advertisement expenses. GROUND

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

Bench: Shri Amit Shukla & Shri Prashant Maharishi

2 to 12) 14. Grounds 3.1 to 3.6 taken by the appellant in its appeal for AY 2005-06 are as below: GROUND NO. 3.1: The AO/CIT(A) has erred by not providing reasons for rejecting the analysis undertaken by the appellant for benchmarking the international transaction pertaining to reimbursement of advertisement expenses. GROUND