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

HEADSTRONG SERVICES INDIA PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal is partly allowed

Bench: Shri R.S. Syal, Am & Shri Kuldip Singh, Jm Assessment Year : 2008-09

section 92C(2), the ALP in relation to the international transaction shall be determined as under : - `(e) transactional net margin method, by which,— (i) the net profit margin realised by the enterprise from an international transaction entered into with an associated 11 enterprise is computed in relation to costs incurred or sales effected or assets employed or to be employed

MICROSOFT INDIA (R&D) PVT. LTD.,NEW DELHI vs. DCIT, CIRCLE-16(2), NEW DELHI

In the result, appeal of the assessee for Assessment Year 2014-15 and 2015-16 is partly allowed

Bench: Shri Kul Bharat & Shri Prashant Maharishi(Through Video Conferencing)

house property. 3. The assessee has raised the following grounds of appeal for Ay 2014-15 and similar grounds are also for AY 2015-16:- ITA. No. 8229/Del/2018 (Assessment year: 2014-15) : “1. The order passed by the Assistant Commissioner of Income Tax, Transfer Pricing- 2(2)(2) („Ld. TPO‟), draft assessment order passed by Deputy Commissioner of Income

(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

EDAG ENGINEERING & DESIGN INDIA PVT. LTD.,NEW DELHI vs. ITO, NEW DELHI

In the result, the appeal is allowed

Bench: : Shri I.C. Sudhir & Shri L.P. Sahu

property rights were held by their parent/group companies, the Assessee was in effect manufacturing for its related enterprise and, therefore, payment of any royalty on sales would be unreasonable. The TPO made observations to the effect that the payment of royalty had, in fact, inflated the operating costs and was 'Villain of the piece". 3.4 The Assessing Officer passed

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

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. 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. 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

PRADEEP WIG,NEW DELHI vs. ACIT CENTRAL CIRCLE-5, NEW DELHI

The appeals of the Revenue are dismissed

Bench: Shri M. Balaganesh & Shri Anubhav Sharma

house or flat) and owned by a ‘non- natural person’ (NNP). A non-natural person is a corporate entity, such as a company, limited liability partnership, trust or investment scheme. To be classed as a dwelling, the property must be: • Used exclusively or in part as a residence • In the process of being adapted or constructed as a residence

M/S. DABUR INDIA LTD.,NEW DELHI vs. ADDL.CIT, NEW DELHI

In the result, the appeals filed by the Revenue are partly allowed and the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri R.K. Panda & Ms Suchitra Kamble

section 92 of the IT Act. It is his submission that so far as agreement with Dabur Nepal Pvt. Ltd., Nepal is concerned, the assessee is having 97.5% of shareholding in Dabur Nepal Pvt. Ltd., Nepal directly/indirectly and, thus, it could not have received any royalty from itself. It is his submission that the marketing agreement dated 05.11.1992 which

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

In the result, the appeals filed by the Revenue are partly allowed and the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri R.K. Panda & Ms Suchitra Kamble

section 92 of the IT Act. It is his submission that so far as agreement with Dabur Nepal Pvt. Ltd., Nepal is concerned, the assessee is having 97.5% of shareholding in Dabur Nepal Pvt. Ltd., Nepal directly/indirectly and, thus, it could not have received any royalty from itself. It is his submission that the marketing agreement dated 05.11.1992 which

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

In the result, the appeals filed by the Revenue are partly allowed and the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri R.K. Panda & Ms Suchitra Kamble

section 92 of the IT Act. It is his submission that so far as agreement with Dabur Nepal Pvt. Ltd., Nepal is concerned, the assessee is having 97.5% of shareholding in Dabur Nepal Pvt. Ltd., Nepal directly/indirectly and, thus, it could not have received any royalty from itself. It is his submission that the marketing agreement dated 05.11.1992 which

M/S. DABUR INDIA LTD.,NEW DELHI vs. ADDL.CIT, NEW DELHI

In the result, the appeals filed by the Revenue are partly allowed and the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri R.K. Panda & Ms Suchitra Kamble

section 92 of the IT Act. It is his submission that so far as agreement with Dabur Nepal Pvt. Ltd., Nepal is concerned, the assessee is having 97.5% of shareholding in Dabur Nepal Pvt. Ltd., Nepal directly/indirectly and, thus, it could not have received any royalty from itself. It is his submission that the marketing agreement dated 05.11.1992 which

MICROSOFT INDIA (R&D) PRIVATE LIMITED,NEW DELHI vs. NEAC, NEW DELHI

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

Bench: Shri Shamim Yahya & Shri Saktijit Deyassessment Year: 2016-17

Section 92C(3) of the Act have been satisfied before disregarding the ALP determined by the Appellant and proceeded to determine the ALP himself. Part II - Corporate tax matters 4 15. That on the facts and in law, the Ld. AO and the Hon'ble DRP was not justified and have erred by taxing gross composite rental income

DCIT, NEW DELHI vs. M/S EXXON MOBIL LUBRICANTS P. LTD., NEW DELHI

In the result, the appeal filed by the Revenue is partly allowed for statistical purposes

Bench: Shri R.K. Panda & Ms Suchitra Kambleassessment Year: 2004-05 Dcit, Vs. Exxon Mobil Lubricants P. Ltd., Circle-11(1), Ernst & Young Tower, New Delhi. B-26, Qutab Institutional Area, New Delhi. Pan Aabce0207H (Appellant) (Respondent) Assessee By : Shri S.D. Kapila, Advocate Shri R.R. Maurya, Advocate Revenue By : Shri H.K. Choudhary, Cit- Dr Order Per R.K. Panda, Am:

92C 8 of the Act. It is only under circumstances where the transactions are so closely interrelated that they are not capable of being evaluated separately, all the transactions may be grouped together. I have considered the submission of the appellant in this regard and I am of the view that Indian transfer pricing regulations requires each international transaction

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

MICROSOFT INDIA (R&D) PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

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

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

Section 92C(3) of the Act have been satisfied before disregarding the arm’s length price determined by the Appellant and proceeding to determine the arm’s length price himself. Part II - Corporate tax matters 15. That on the facts and in law, the Ld. AO and the DRP was not justified and have erred by taxing gross composite rental

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

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