M/S. BECHTEL INDIA PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

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

Bench: Shri S.V. Mehrotra & Shri Chandra Mohan Garg

penalty proceedings under section 271(1)(c) of the Act.” Ground no. 3 to 3.5 of the assessee 3. Apropos these grounds, we have heard arguments of both the sides and carefully perused the relevant material placed on record. 4. Ld. Counsel of the assessee submitted that the ld. DRP and the AO erred in making an addition

VODAFONE IDEA LTD. (EARLIER KNWON AS VODAFONE MOBILE SERVICES LTD.),MUMBAI vs. ACIT,. CIRCLE-26(2), NEW DELHI

In the result, all above said grounds are allowed for statistical purpose

Bench: Shri S. Rifaur Rahman & Shriyogesh Kumar U.S.Vodafone Idea Ltd Vs. Acit, (Earlier Known As Vodafone Circle-26(2), Mobile Services Ltd) New Delhi 10Th Floor, Birla Centurion, Century Mills Compound, Pandurang Budhkar Marg, Worli, Mumbai, Maharastra (Appellant) (Respondent) Pan: Aaacb2100P

92A of the Act. We repeat that this assessee and its overseas associate enterprise admittedly fall in this category. There is further no quarrel about its Deltamethrin sale to be in the nature of international transactions u/s. 92B of theAct. We notice that section 92C(1) of the Act postulates arms length price computation by applying six methods namely; comparable

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

2)(b). 9. The learned Assessing Officer erred on facts and in law initiating penalty proceedings u/s 271(1)(c) on account of certain additions. Page 37 of 112 ITA No.-654/Del/2015. Haldor Topsoe India Pvt. Ltd., New Delhi. 10. The learned Assessing Officer has erred in not granting 100% of the eligible profit as deduction u/s

PCL FOODS PVT. LTD.,GURGAON vs. ADDI CIT, NATIONAL E- ASSESMENT CENTRE, NEW DELHI

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

Bench: Ms. Madhumita Roy & Shri Brajesh Kumar Singh[Assessment Year: 2016-17] Pcl Foods Private Limited, Additional / Joint/ Unit No.-219, Plot No. 2, Deputy/Assistant Vardhman Crown Mall, Lsc, Vs Commissioner Of Income Sector 19, Dwarka, New Tax/ Income Tax Officer, Delhi-110075. National E-Assessment Centre, Delhi. Pan- Aahcp3493L Assessee Revenue

92A(1)(a) r.w.s. Agricultural Products. Casio Street, 92S(2)(a) of Wickhams Cay I, Income Tax Act, Road Town, Tortoia. 1961 British Virgin Islands ITA No.- 442/Del/2021 PCL Foods Pvt. Ltd. 4.1 The TPO further noted that as per the TP documentation and other documents submitted by the assessee company during the TP audit proceedings for the A.Y.2016-17, following

SILVERPLASS HOLDINGS LTD.,MUMBAI vs. ACIT, CIRCLE- 3(1)(2), INTERNATIONAL TAXATION, NEW DELHI

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

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

92A(2)(b) of the Act. Page 2 of 12 ITA No. 7396/DEL/2018 [A.Y 2015-16] Silverplass Holdings Vs. ACIT 3:0 The Ld. AO erred in denying the DTAA benefit of lower tax rate on interest income of the assessee, which ware allowed in earlier year 3:1 The AO erred in disallowing the DTAA benefit of lower

M/S. SIS LIVE,GURGAON vs. ACIT, NEW DELHI

In the result the ground No

Bench: I.C.Sudhir & Shri Prashant Maharishisis Live Acit, C/O. Srbc & Associates Llp, Central Circle-17, Room No. Vs. Golf View Corporate Tower B, 356, E-2, Sector-42, Sector Road, Gurgaon Pan:Abrfs4787L (Appellant) (Respondent)

penalty proceedings u/s 271G for failure to furnish information or documents u/s 92D of the Income Tax Act, 1961. Page 6 of 19 13.4 Without prejudice to the above finding in this case, since, the Firm is following Cash System of accounting, no payment i.r.o the international Transactions w.r.t. SIS OB and Fatpipe as discussed above, shall be allowed

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)

92A taxpa the by the adopt order A.O. nce payer tion enterp yer taxpa Transf ed of the and as per rise yer er by A.O. natur section and Pricing TPO e 92B the Officer of and countr under busin assess y section ess ment in 92CA year which (3) it is reside nt ANNEXURE II Order under section

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)

92A taxpa the by the adopt order A.O. nce payer tion enterp yer taxpa Transf ed of the and as per rise yer er by A.O. natur section and Pricing TPO e 92B the Officer of and countr under busin assess y section ess ment in 92CA year which (3) it is reside nt ANNEXURE II Order under section

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

In the result, the appeal of the assessee is allowed

Bench: Ms. Sushma Chowladr. B. R. R. Kumarita No. 6813/Del/2017 : Asstt. Year : 2012-13 Samsung India Electronics Pvt. Ltd. Vs Additional Commissioner Of 20Th -24Th Floors, Dlf Two Horizon Income Tax, Special Range-8 Center, Sector-13, Gurgaon, New Delhi-110002 Haryana-122002 (Appellant) (Respondent) Pan No. Aaacs5123K Assessee By : Sh. Himanshu Sinha, Adv. Revenue By : Sh. H. K. Choudhary, Cit Dr & Date Of Hearing: 04.12.2019 Date Of Pronouncement: 07.01.2020

penalty proceedings under Section 271(1)(c) and Section 271AA of the Act for furnishing of inaccurate particulars and concealment of income. Each of the above grounds are independent and without prejudice to the other grounds of appeal preferred by the Appellant.” 3. Ground Nos. 1 & 2 are comprehensive, 4. Ground nos. 3 to 13 relates to adjustment on account

M/S. SHOWA INDIA PVT. LTD.,FARIDABAD vs. DCIT, NEW DELHI

In the result the appeal filed by the assessee stands allowed for statistical purposes

Bench: Shri N. K. Saini & Smt. Beena A. Pillaii.T.(Tp) No.166/Del.2013 (Assessment Year 2008-09) M/S. Showa India Pvt. Ltd., Vs. Dcit, Circle 8(1), 23-32, Sector 58, New Delhi Faridabd, Haryana-121002 Gir / Pan :Aabce5725G (Appellant) (Respondent)

92A of the Act. . 2.4. That on the facts of the case the Ld. AO has grossly erred in making an addition amounting to Rs.12,829,790/- twice, the same already being included in the aforesaid additions amounting to Rs.23,664,501/-. 3. That on the facts of the case the Ld. AO has grossly erred in making an addition