THE PR. COMMISSIONER OF INCOME TAX -6 vs. DEPUTY COMMISSIONER OF INCOME TAX

The appeals are disposed of in above terms

section 92B(2) i.e., there exists a prior agreement 2021:DHC:11-DB ITA 247/2019 and connected matters Page 11 of 17 in relation to such transaction between Citigroup Inc. (third person) and Wipro Ltd. (associated enterprise). In the light of this structure of transaction, it ceases to be uncontrolled transaction and, hence, Wipro Technology Services Ltd., disqualifies to become

THE PR. COMMISSIONER OF INCOME TAX -6 vs. DEPUTY COMMISSIONER OF INCOME TAX

The appeals are disposed of in above terms

section 92B(2) i.e., there exists a prior agreement 2021:DHC:11-DB ITA 247/2019 and connected matters Page 11 of 17 in relation to such transaction between Citigroup Inc. (third person) and Wipro Ltd. (associated enterprise). In the light of this structure of transaction, it ceases to be uncontrolled transaction and, hence, Wipro Technology Services Ltd., disqualifies to become

PERFETTI VAN MELLE INDIA PVT. LTD.,GURGAON vs. ACIT, CIRCLE-3(1), GURGAON

In the result, the additional ground raised by the assessee is allowed

Bench: The Income Tax Appellate Tribunal, Delhi Bench “I-2”, New Delhi

property of the AE. For instance, ‘Alpenliebe, Mangofillz’, a variant of one of the brands owned by the AE that was developed in India, is registered as a trademark in the name of the AE. The TPO came to the conclusion that the 11 assessee incurred AMP expenses for promoting the brand / trade name which was owned

FUJITSU INDIA P.LTD,NEW DELHI vs. DCIT, NEW DELHI

The appeal of the assessee is allowed

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year: 2013-14 Fujitsu India P. Ltd., Vs National Faceless Assessment Rectangale-1, D-4, Centre, District Centre, New Delhi. Saket, New Delhi – 110 019. Pan: Aaacf4170D (Appellant) (Respondent) Assessee By : Shri K.M. Gupta, Advocate, Ms Shruti Khimta, Ar & Shri Kaskaran Singh, Ca Revenue By : Shri S.K. Jadhav, Cit-Dr Date Of Hearing : 07.01.2025 Date Of Pronouncement : 24.01.2025 Order

house hold product but is engaged in trading of IT products and provision of IT solutions and services in India. Which is a niche area and restricted cutomer base. Therefore that all the more needed to put on record on the basis of some material that AMP expenses were integral part of assessee’s business functions 11 to create some

TUPPERWARE INDIA PRIVATE LIMITED,NEW DELHI vs. DCIT,CIRCLE-25(1), NEW DELHI

In the result, the appeal of the assessee for AY 2018-19 is partly allowed for statistical purposes

Bench: Shri Mahavir Singh & Shri M. Balaganesh

House, 15 Appeal Centre (NFAC), Tolstoy Marg, Connaught Place, Delhi New Delhi (Appellant) (Respondent) PAN: AAACT3770D Assessee by : Shri Rohit Tiwari, Adv Ms. Tanya, Adv Ms. Shivani, Adv Revenue by: Shri S. K. Jadav, CIT DR Date of Hearing 20/01/2025 Date of pronouncement 17/04/2025 O R D E R PER M. BALAGANESH, AM 1. Assessee M/s. Tupperware Aker Powergas

TUPPERWARE INDIA PRIVATE LIMITED,NEW DELHI vs. ACIT, CIRCLE-25(1) , NEW DELHI

In the result, the appeal of the assessee for AY 2018-19 is partly allowed for statistical purposes

Bench: Shri Mahavir Singh & Shri M. Balaganesh

House, 15 Appeal Centre (NFAC), Tolstoy Marg, Connaught Place, Delhi New Delhi (Appellant) (Respondent) PAN: AAACT3770D Assessee by : Shri Rohit Tiwari, Adv Ms. Tanya, Adv Ms. Shivani, Adv Revenue by: Shri S. K. Jadav, CIT DR Date of Hearing 20/01/2025 Date of pronouncement 17/04/2025 O R D E R PER M. BALAGANESH, AM 1. Assessee M/s. Tupperware Aker Powergas

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

In the result, appeal of the assessee in ITA No

Bench: Shri N.K. Billaiya & Ms. Suchitra Kamble[A.Y 2014-15]

House Circle 2(2) Connaught Place New Delhi New Delhi PAN: AAACA 0364 L [Appellant] [Respondent] Assessee by : Shri Tarandeep Singh, Adv Revenue by : Shri Surender Pal, CIT-DR Date of Hearing : 02.03.2021 Date of Pronouncement : 08.03.2021 ORDER PER N.K. BILLAIYA, ACCOUNTANT MEMBER, This appeal by the assessee is preferred against the order dated 29.10.2018 framed u/s 143(3) r.w.s

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

Bench: Shri Amit Shukla & Prashant Maharishi

house property number to income from 155-160 business and profession 8 Deletion of Decided in Decided in Para number Dismissed addition on favour of favour of the 13 of the order account of the assesse assesse as per notional as per paragraph rent/additional paragraph number 20 of annual letting number the order vale in respect

TUPPERWARE INDIA PRIVATE LIMITED,CONNAUGHT PLACE NEW DELHI vs. NATIONAL FACELESS ASSESSMENT CENTRE THROUGH DEPUTY COMMISSIONER OF INCOME TAX, IP ESTATE NEW DELHI

The appeal is allowed partly

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year : 2020-21

House, Centre, 15 Tolstoy Marg, New Delhi. through Connaught Place, DCIT, Circle 25(1), New Delhi-110001. New Delhi. PAN: AAACT3770 D (Appellant) (Respondent) Assessee represented by : Shri Rohit Tiwari, Adv.; Ms. Shivani, Advocate & Shri Shobhit Tiwari, Advocate Department represented by : Shri S.K. Jadhav, CIT-DR Date of hearing : 21.08.2025 Date of pronouncement

SONA BLW PRECISION FORGINGS LTD.,NEW DELHI vs. DCIT, NEW DELHI

Bench: Shri O.P. Kant & Ms. Suchitra Kamble[Through Video Conferencing]

property" shall include— a) marketing related intangible assets, such as, trademarks, trade names, brand names, logos; (b) technology related intangible assets, such as, process patents, patent applications, technical documentation such as laboratory notebooks, technical know-how; (c) artistic related intangible assets, such as, literary works and copyrights, musical compositions, copyrights, maps, engravings; d) data processing related intangible assets, such

SONA OKEGAWA PRECISION FORGINGS LTD.,NEW DELHI vs. DCIT, NEW DELHI

Bench: Shri O.P. Kant & Ms. Suchitra Kamble[Through Video Conferencing]

property" shall include— a) marketing related intangible assets, such as, trademarks, trade names, brand names, logos; (b) technology related intangible assets, such as, process patents, patent applications, technical documentation such as laboratory notebooks, technical know-how; (c) artistic related intangible assets, such as, literary works and copyrights, musical compositions, copyrights, maps, engravings; d) data processing related intangible assets, such

PERFETTI VAN MELLE INDIA PVT. LTD.,GURGAON vs. ACIT, CIRCLE-3(1), GURGAON

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

Bench: Shri Anil Chaturvedi & Shri Yogesh Kumar U.S.

92B of the Act, it could be inferred that Transfer Pricing 9 Perfetti Van Melle India, Manesar regulations would be applicable to any ‘transaction’, being an arrangement, understanding or action in concert, inter alia, in the nature of purchase, sale or lease of tangible or intangible property or any other transaction having bearing on profits, income, losses or assets

LG ELECTRONICS INDIA PVT. LTD.,NEW DELHI vs. ADDL. CIT, SPECIAL RANGE- 5, NEW DELHI

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

92B read with Section 92F (v), an international transaction could include an arrangement, understanding or action in concert, this cannot be a matter of inference. There has to be some tangible evidence on record to show that two parties have "acted in concert". XXX 37. The provisions under Chapter X do envisage a 'separate entity concept'. In other words, there

LG ELECTRONICS INDIA PRIVATE LIMITED,MATHURA ROAD, NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

92B read with Section 92F (v), an international transaction could include an arrangement, understanding or action in concert, this cannot be a matter of inference. There has to be some tangible evidence on record to show that two parties have "acted in concert". XXX 37. The provisions under Chapter X do envisage a 'separate entity concept'. In other words, there

DCIT, NOIDA vs. M/S. L.G. ELECTRONICS INDIA PVT. LTD., GREATER NOIDA

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

92B read with Section 92F (v), an international transaction could include an arrangement, understanding or action in concert, this cannot be a matter of inference. There has to be some tangible evidence on record to show that two parties have "acted in concert". XXX 37. The provisions under Chapter X do envisage a 'separate entity concept'. In other words, there

LG ELECTRONICS INDIA PRIVATE LIMITED ,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

92B read with Section 92F (v), an international transaction could include an arrangement, understanding or action in concert, this cannot be a matter of inference. There has to be some tangible evidence on record to show that two parties have "acted in concert". XXX 37. The provisions under Chapter X do envisage a 'separate entity concept'. In other words, there

LG ELECTRONICS INDIA PVT. LTD.,NEW DELHI vs. ADDL. CIT, SPECIAL RANGE- 5, NEW DELHI

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

92B read with Section 92F (v), an international transaction could include an arrangement, understanding or action in concert, this cannot be a matter of inference. There has to be some tangible evidence on record to show that two parties have "acted in concert". XXX 37. The provisions under Chapter X do envisage a 'separate entity concept'. In other words, there

DCIT, CIRCLE-13(1), NEW DELHI vs. LG ELECTRONICS INDIA PVT. LTD., DELHI

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

92B read with Section 92F (v), an international transaction could include an arrangement, understanding or action in concert, this cannot be a matter of inference. There has to be some tangible evidence on record to show that two parties have "acted in concert". XXX 37. The provisions under Chapter X do envisage a 'separate entity concept'. In other words, there