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)

3 shall exercise such powers and perform such function of Transfer Pricing Officers as mentioned in Section 92CA for the purpose of sections 92C and 92D of the Act, in respect of persons or classes of persons mentioned in column 5:" 5. It was submitted by Mr. Mahabir Singh, learned Senior Advocate that the expression "…..the Assessing Officer

M/S. HONDA SIEL POWER PRODUCTS LTD.,GAUTAM BUDH NAGAR vs. DCIT, NEW DELHI

In the result, both the appeals of the assessee-company are partly allowed for statistical purposes

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

92C of the Act. 3.20 That the assessing officer/TPO erred on facts and in law in failing to appreciate that the appellant has long-term rights to use the trademark/ licensed intangibles and reaps all the benefits of the said AMP expenses and is thus the economic owner of any related marketing intangible. 3.21 That the assessing officer/TPO erred

(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

DCIT, NEW DELHI vs. M/S. BIO RAD LABORATORIES (INDIA) PVT. LTD., NEW DELHI

In the result the appeal of the revenue is dismissed

Bench: Shri I.C.Sudhir & Shri Prashant Maharishi

92C(3) of the Act rendering his order void. During the course of hearing the ld DR has submitted that Hon’ble Karnataka High Court has stayed the above judgment and therefore, the decision of the first appellate authority is erroneous as it relied on the stayed judgment. The Hon’ble Karnataka High Court vide its order dated

COMPASS INDIA SUPPORT SERVICES PRIVATE LTD. ,GURGAON vs. DCIT, CIRCLE-4(2), DELHI

92C of the Act, and\n2 That on the facts and circumstances of the case, and in law the Ld. AO has grossly\nerred in proposing to initiate penalty proceedings under section 270A of the Act\nAll the above grounds are without prejudice to each other The Appellant craves leave\nto add, amend, vary, omit or substitute

COMPASS INDIA SUPPORT SERVICES PRIVATE LIMITED,GURGAON vs. DCIT, CIRCLE-4(2), DELHI

92C of the Act, and\n2 That on the facts and circumstances of the case, and in law the Ld. AO has grossly\nerred in proposing to initiate penalty proceedings under section 270A of the Act\nAll the above grounds are without prejudice to each other The Appellant craves leave\nto add, amend, vary, omit or substitute

DCIT, NEW DELHI vs. M/S JSL LTD.,, HISAR

Accordingly, ground number 2 of the appeal of the learned AO for 2007 – 08 is dismissed

Bench: Smt Diva Singh & Shri Prashant Maharishi

92C(2) of the Act. 3. That the Commissioner of Income Tax (Appeals) erred on facts and in law in sustaining addition of Rs. 70,95,787 on account of the alleged difference in the arm‘s length price of international transactions of interest charged on loan given to the associated enterprise, PT Jindal Indonesia by applying the interest rate

JINDAL STAINLESS LTD.,HISAR vs. DCIT, NEW DELHI

Accordingly, ground number 2 of the appeal of the learned AO for 2007 – 08 is dismissed

Bench: Smt Diva Singh & Shri Prashant Maharishi

92C(2) of the Act. 3. That the Commissioner of Income Tax (Appeals) erred on facts and in law in sustaining addition of Rs. 70,95,787 on account of the alleged difference in the arm‘s length price of international transactions of interest charged on loan given to the associated enterprise, PT Jindal Indonesia by applying the interest rate

ECOENERGY INSIGHTS LTD ( FORMERLY KNOWN AS CHUBB ALBA CONTROL SYSTEMS P.LTD),NEW DELHI vs. DCIT, CIRCLE-4(2), NEW DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaecoenergy Insights Ltd., Vs. Dcit, (Formerly Known As Chubb Alba Control Circle 4 (2), Systems P. Ltd.), New Delhi. Ground Floor, 18, Netaji Subhash Marg, Daryaganj, New Delhi – 110 002. (Pan :Aaaca0031C) (Appellant) (Respondent) Assessee By : Shri Nageshwar Rao, Advocate Shri Parth, Advocate Shri Pratik Rath, Advocate Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 12.08.2025 Date Of Order : 10.11.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Assessment Order Dated 25.07.2022Passed By The Assessment Unit, Income Tax Department Under Section 147 Read With Section 144C(13) R.W.S. 144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Ay 2018-19 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act.

92C. In sub-section 3 of section 144B, roles of Technical unit is clearly spelt out according to which, functions of technical unit includes assistance or advice on transfer pricing issues. During the course of performing such function, the technical unit can obtain advice from the TPO on the issue of determination of Arm’s Length price

JAS FORWARDING WORLDWIDE PVT. LTD.,GURGAON vs. DCIT, NEW DELHI

In the result appeal of the assessee for assessment year 2011 – 12 is allowed for statistical purposes

Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing)

3) of the Act and by the Ld. AO in his draft assessment order. On the facts and in the circumstances of the case, the Ld. TPO and the Ld. AO have erred in proposing and Hon'ble DRP has further erred in confirming the adjustment of Rs. 29,09,79,383 (including Rs 24,68,35,593 under Section

JAS FORWARDING WORLDWIDE PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result appeal of the assessee for assessment year 2011 – 12 is allowed for statistical purposes

Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing)

3) of the Act and by the Ld. AO in his draft assessment order. On the facts and in the circumstances of the case, the Ld. TPO and the Ld. AO have erred in proposing and Hon'ble DRP has further erred in confirming the adjustment of Rs. 29,09,79,383 (including Rs 24,68,35,593 under Section

COMVERSE NETWORK SYSTEMS INDIA PVT. LTD.,GURGAON vs. ACIT, GURGAON

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

Bench: Sh. I.C. Sudhir & Sh. O.P. Kantassessment Year: 2008-09 Vs. Acit, Circle-1(1), Gurgaon M/S. Comverse Network Systems India Pvt. Ltd., Dlf Infinity Tower-A, 2Nd Floor, Dlf Cyber City Phase-Ii, Gurgaon Pan : Aabcc3425B (Appellant) (Respondent) Appellant By S/Sh. G.C. Srivastava & Daksh Bhardwaj, Advocates Respondent By Sh. T.M. Shiva Kumar, Cit(Dr) Date Of Hearing 02.11.2016 Date Of Pronouncement 20.01.2017 Order Per O.P. Kant, A.M.: This Appeal By The Assessee Is Directed Against Order Dated 23/10/2012 Passed By The Assessing Officer (Ao) , In Compliance To The Direction Of The Dispute Resolution Panel ( Drp) , Under Section 143 (3) Read With Section 144C Of The Income- Tax Act, 1961 (For Short ‘The Act’), In Respect Of Assessment Year 2008-09 Raising Following Grounds: “On The Facts & Circumstances Of The Case & In Law, The Learned Assessing Officer (“Ao") Has Erred In Passing The Assessment Order Under Section 143(3) Read With Section 144C Of The Income-Tax Act, 1961 (“The Act”) After Considering The Adjustments Proposed By The Learned Transfer Pricing Officer (“Tpo”) In His Order Passed Under Section 92Ca(3) Of The Act & Subsequently Confirmed By The Hon’Ble Dispute Resolution Panel (“Drp”).

92C of Act for the purposes of computing the ALP under section 92F of the Act. 14. The DRP has erred in confirming the additions proposed by the learned AO and erred in rejecting the objection filed against the draft assessment order. The Appellant craves leave to add, amend, vary, omit or substitute any of the aforesaid grounds

WRIGLEY INDIA PRIVATE LIMITED,DELHI vs. ACIT,CIRCLE-27(2), DELHI

section 92D of\nthe Act read with Rule 10D of the Income-tax Rules, 1962 ('the Rules');\n3. 3. distorting the economic and comparability analysis undertaken by the\nAppellant in the TP Study and conducting a fresh comparability analysis based on\napplication of the erroneous additional /revised filters in determining the ALP and\nrejecting the filters applied

DCIT, CIRCLE-25(1), NEW DELHI vs. WRIGLEY INDIA P.LTD, NEW DELHI

section 92D of\nthe Act read with Rule 10D of the Income-tax Rules, 1962 ('the Rules');\n3. 3. distorting the economic and comparability analysis undertaken by the\nAppellant in the TP Study and conducting a fresh comparability analysis based on\napplication of the erroneous additional /revised filters in determining the ALP and\nrejecting the filters applied

JCIT, CIRCLE-27(2), NEW DELHI vs. WRIGLEY INDIA PVT. LTD., NEW DELHI

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

section 92D of\nthe Act read with Rule 10D of the Income-tax Rules, 1962 ('the Rules');\n3. 3. distorting the economic and comparability analysis undertaken by the\nAppellant in the TP Study and conducting a fresh comparability analysis based on\napplication of the erroneous additional /revised filters in determining the ALP and\nrejecting the filters applied

WRIGLEY INDIA PRIVATE LIMITED,DELHI vs. ACIT,CIRCLE-27(2), DELHI

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

section 92D of\nthe Act read with Rule 10D of the Income-tax Rules, 1962 ('the Rules');\n3. 3. distorting the economic and comparability analysis undertaken by the\nAppellant in the TP Study and conducting a fresh comparability analysis based on\napplication of the erroneous additional /revised filters in determining the ALP and\nrejecting the filters applied

DCIT, CIRCLE- 25(1), NEW DELHI vs. WRIGLEY INDIA PVT. LTD., NEW DELHI

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

section 92D of\nthe Act read with Rule 10D of the Income-tax Rules, 1962 ('the Rules');\n3. 3. distorting the economic and comparability analysis undertaken by the\nAppellant in the TP Study and conducting a fresh comparability analysis based on\napplication of the erroneous additional /revised filters in determining the ALP and\nrejecting the filters applied

DCIT, CIRCLE-25(1), NEW DELHI vs. WRIGLEY INDIA P.LTD, NEW DELHI

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

section 92D of\nthe Act read with Rule 10D of the Income-tax Rules, 1962 ('the Rules');\n3. 3. distorting the economic and comparability analysis undertaken by the\nAppellant in the TP Study and conducting a fresh comparability analysis based on\napplication of the erroneous additional /revised filters in determining the ALP and\nrejecting the filters applied

WRIGLEY INDIA PVT. LTD.,206, OKHLA INDUSTRIAL ESTATE, PHASE-3,NEW DELHI-110020 vs. DCIT, CIRCLE 27(2), NEW DELHI

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

section 92D of\nthe Act read with Rule 10D of the Income-tax Rules, 1962 ('the Rules');\n\n3. 3. distorting the economic and comparability analysis undertaken by the\nAppellant in the TP Study and conducting a fresh comparability analysis based on\napplication of the erroneous additional /revised filters in determining the ALP and\nrejecting the filters applied