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

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

3) of the Act provides that – "Any term used but not defined in this Act or in the agreement referred to in sub-section (1) shall, unless the context otherwise requires, and is not inconsistent with the provisions of this Actor the agreement. have the same meaning as assigned to it in the notification issued by the Central Government

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

3 of the show cause reply submitted in this office on 04.10.2016, assessee himself admits that one among the major functions of the assessee is the implementation of global direct selling/ marketing policy. Assessee in its submissions has admitted stated many times that policy formulation and brand promotion is the work done by AEs. Since, it is clear from that

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

3 of the show cause reply submitted in this office on 04.10.2016, assessee himself admits that one among the major functions of the assessee is the implementation of global direct selling/ marketing policy. Assessee in its submissions has admitted stated many times that policy formulation and brand promotion is the work done by AEs. Since, it is clear from that

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

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.

3), the assessing officer in the impugned draft assessment order has proposed initiation of penalty proceedings under section 271AA of the Act alleging non-disclosure of certain international transactions.In this regard, he brought to our notice the provisions of 45 Section 271AA of the Act which read as under: “Penalty for failure to keep and maintain information and document

HEWITT ASSOCIATES (INDIA) PVT. LTD.,GURGAON vs. ACIT, NEW DELHI

In the result, the appeal of the assesee is treated as allowed for statistical purposes

Bench: Shri R.K. Panda & Ms. Astha Chandraasstt. Year : 2007-08

92C (2) of the Act, while determining the arm's length price of the international transactions of the Appellant. 2.13 By not appreciating that there was no intention whatsoever on the part of the Appellant to shift profits outside India by under-reporting revenue since the Appellant was eligible to claim 100 percent of such profits as tax exemption under

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

3% charged by the TPO and accordingly restricted the arm’s length price at Rs.22.58 lakhs. 81. So far as Dabur Nepal Pvt. Ltd., Nepal is concerned, the CIT(A) observed that Rate of 3% is mentioned in the amended agreement and the assessee could not meet its obligation to bear entire marketing expenses and therefore, Dabur Nepal

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

3% charged by the TPO and accordingly restricted the arm’s length price at Rs.22.58 lakhs. 81. So far as Dabur Nepal Pvt. Ltd., Nepal is concerned, the CIT(A) observed that Rate of 3% is mentioned in the amended agreement and the assessee could not meet its obligation to bear entire marketing expenses and therefore, Dabur Nepal

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

3% charged by the TPO and accordingly restricted the arm’s length price at Rs.22.58 lakhs. 81. So far as Dabur Nepal Pvt. Ltd., Nepal is concerned, the CIT(A) observed that Rate of 3% is mentioned in the amended agreement and the assessee could not meet its obligation to bear entire marketing expenses and therefore, Dabur Nepal

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

3% charged by the TPO and accordingly restricted the arm’s length price at Rs.22.58 lakhs. 81. So far as Dabur Nepal Pvt. Ltd., Nepal is concerned, the CIT(A) observed that Rate of 3% is mentioned in the amended agreement and the assessee could not meet its obligation to bear entire marketing expenses and therefore, Dabur Nepal

HERO MOTOCROP LTD.,NEW DELHI vs. ACIT, CIRCLE- 11(1), NEW DELHI

The appeal of the assessee is partly allowed

Bench: Shri Sudhanshu Srivastava & Shri O.P. Kantassessment Year: 2015-16

92C of the Act, and held the impugned inter-unit purchases to be not at arm’s length price on the ground that the profit margin of the non-eligible units, viz., Gurgaon and Dharuhera unit at 7.69% and 7.03% respectively ought to have been charged on such transfer of components/semi-finished goods. Accordingly, the TPO/AO came to the conclusion that

FIL INDIA BUSINESS & RESEARCH PVT. LTD. ,DELHI vs. DCIT, CIRCLE 2(1), C.R BUILDING , DELHI

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

House,\nBarakhamba Road,\nNew Delhi-110001\nPAN:AABCF1572C\n(Appellant)\nDCIT,\nNational Faceless\nVs. Assessment Centre,\nDelhi.\n(Respondent)\n\nAssessee by\nShri Ravi Sharma, Adv. &\nShri Kshitij Bansal, CA\nDepartment by\nShri S.K. Jhadav, CIT-DR\n\nDate of hearing\n03.04.2025\nDate of pronouncement\n25.06.2025\n\nORDER\n\nPER MANISH AGARWAL, AM:\n\nThe present appeal is filed

HERO MOTO CORP LTD.,NEW DELHI vs. NEAC, DELHI

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

92C of the Act, and held the impugned inter-unit purchases to be not at arm‟s length price on the ground that the profit margin of the non-eligible units, viz., Dharuhera, Gurgaon and Neemran aunits at 7.77%, 4.13% and 18.24% respectively ought to have been charged on such transfer of components. Accordingly, the TPO/AO concluded that the appellant

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Properties P. Ltd. v. DCIT: 343 ITR 141 (Del) 23 - Avtee Ladi v, DCIT: 370 ITR 611 (Del) - CIT v. Motor & General Finance: 184 Taxman 465 (Del.) DCIT vs. Lotus Hearbals Pvt. Ltd. In the case of Calcutta Discount Co. Ltd 15. ITO 41 ITR 191 (SC), the Hon'ble Apex Court, held that-(i) it is the assessee

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Properties P. Ltd. v. DCIT: 343 ITR 141 (Del) 23 - Avtee Ladi v, DCIT: 370 ITR 611 (Del) - CIT v. Motor & General Finance: 184 Taxman 465 (Del.) DCIT vs. Lotus Hearbals Pvt. Ltd. In the case of Calcutta Discount Co. Ltd 15. ITO 41 ITR 191 (SC), the Hon'ble Apex Court, held that-(i) it is the assessee

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Properties P. Ltd. v. DCIT: 343 ITR 141 (Del) 23 - Avtee Ladi v, DCIT: 370 ITR 611 (Del) - CIT v. Motor & General Finance: 184 Taxman 465 (Del.) DCIT vs. Lotus Hearbals Pvt. Ltd. In the case of Calcutta Discount Co. Ltd 15. ITO 41 ITR 191 (SC), the Hon'ble Apex Court, held that-(i) it is the assessee