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. ADDL. CIT, NEW DELHI

In the result, appeal of the assessee is allowed partly for statistical purposes

Bench: Sh. Vijay Pal Rao & Sh. O.P. Kantassessment Year: 2010-11 Vs. Addl. Cit, Range-2, New Delhi M/S. Amadeus India Pvt. Ltd., E- 9, Connaught House, Connaught Place, New Delhi. Pan : Aaaca0364L (Appellant) (Respondent) Appellant By Sh. Tarandeep Singh, Adv. Respondent By Sh. H.S. Choudhary, Cit(Dr) Date Of Hearing 03.08.2017 Date Of Pronouncement 23.10.2017 Order Per O.P. Kant, A.M.:

Housing Ltd. 1.00 12. Tamil Nadu Trade Promotion Organization 0.8 13. Usha Breco Ltd. 4.97 14. Vista Entertainment Ltd. 3.16 15. Adrenalin Esystem Ltd. 6.74 16. Interworld Digital Ltd. 0.10 17. NSE IT Ltd. 0.01 18. Newgen Software Technologies Ltd. 2.03 19. Nucleus Software Exports Ltd. 1.03 20. Powersoft Global Solutions Ltd. 0.35 12 21. Supertech Solutions

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

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

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

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. 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

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

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

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