COMMISSIONER OF INCOME TAX vs. MENTOR GRAPHICS (NOIDA) PVT.LTD

The appeal is allowed

price to the Transfer Pricing Officer. That being the position, it is clear that the Transfer Pricing Officer, in view

DCIT, CIRCLE- 16(2), NEW DELHI vs. MENETA AUTOMOTIVE COMPONENTS PVT. LTD., NEW DELHI

In the result, the appeal of the Revenue is dismissed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

PRICE UNDER SECTION 92 – GUIDELINES TO TRANSFER PRICING OFFICERS AND ASSESSING OFFICERS TO OPERATIONALISE TRANSFER PRICING PROVISIONS AND TO HAVE

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

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

Bench: Shri Prakash Chand Yadav & Manish Agarwalassessment Year: 2011-12 Takata India Pvt Ltd., Vs. Dcit, Circle 25(1), (Now Joyson Anand Abhishek New Delhi Safety Systems Pvt Ltd.,) Plot No.20, Sector-5, Imt Manesar, Gurugram (Haryana)-122050 Pan/Gir No. Aacct 7200 N (Appellant) .. ( Respondent)

Pricing Officer (Transfer Pricing Officer) /Ld.DRP have erred in law in rejecting the transfer pricing methodology adopted by the appellant

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

The appeals are allowed in the above terms, but with no orders as to costs

price. The transfer pricing adjustment envisages the substitution of the price of such international transaction with the ALP. 64. The transfer

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

The appeals are allowed in the above terms, but with no orders as to costs

price. The transfer pricing adjustment envisages the substitution of the price of such international transaction with the ALP. 64. The transfer

ADOBE SYSTEMS SOFTWARE IRELAND LIMITED,IRELAND vs. ACIT CIRCLE 1(1)(1) INTERNATIONAL TAXATION, NEW DELHI

In the result, the appeal of the assessee is treated as allowed for statistical purposes subject to the directions contained in para 11, 18 and 19 above

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2020-21

transfer pricing study and transfer pricing report of Adobe India, and by the fact that the case of the Appellant

MUFG BANK,LTD (EARLIER KNOWN AS THE BANK OF TOKYO MITSUBISHI UFJ LTD.),NEW DELHI vs. ACIT, CIRCLE-2(2)(1) INT. TAXATION, DELHI

In the result, the appeal of the assessee is allowed in above terms

Bench: Shri Pradip Kumar Kedia & Shri Narender Kumar Choudhry

transfer pricing adjustment during remand back transfer pricing assessment proceedings, thereby, violating the principles of natural justice. 1.7 That on the facts

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

TRANSFER PRICING GROUNDS: 4. That the Ld. DRP/Ld. AO/ Additional Commissioner of Income Tax, Transfer Pricing Officer- 3(2)(1) ("Ld. TPO") have

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

TRANSFER PRICING GROUNDS: 4. That the Ld. DRP/Ld. AO/ Additional Commissioner of Income Tax, Transfer Pricing Officer- 3(2)(1) ("Ld. TPO") have

DCIT, CIRCLE-15(2), NEW DELHI vs. LG ELECTRONICS INDIA PVT. LTD., NEW DELHI

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

transfer price as the arm's length price. Then to make a comparison of a horizontal item without segregation would

DCIT, CIRCLE-13(1), NEW DELHI vs. LG ELECTRONICS INDIA PVT. LTD., DELHI

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

transfer price as the arm's length price. Then to make a comparison of a horizontal item without segregation would

LG ELECTRONICS INDIA PVT. LTD.,NEW DELHI vs. ADDL. CIT, SPECIAL RANGE- 5, NEW DELHI

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

transfer price as the arm's length price. Then to make a comparison of a horizontal item without segregation would

M/S LG ELECTRONICS INDIA PVT. LTD.,,NEW DELHI vs. DCIT, NOIDA

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

transfer price as the arm's length price. Then to make a comparison of a horizontal item without segregation would

LG ELECTRONICS INDIA PRIVATE LIMITED ,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

transfer price as the arm's length price. Then to make a comparison of a horizontal item without segregation would

LG ELECTRONICS INDIA PVT. LTD.,NEW DELHI vs. ADDL. CIT, SPECIAL RANGE- 5, NEW DELHI

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

transfer price as the arm's length price. Then to make a comparison of a horizontal item without segregation would

LG ELECTRONICS INDIA PVT. LTD.,NEW DELHI vs. DCIT, CIRCLE-15(2), NEW DELHI

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

transfer price as the arm's length price. Then to make a comparison of a horizontal item without segregation would

DCIT, NOIDA vs. M/S. L.G. ELECTRONICS INDIA PVT. LTD., GREATER NOIDA

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

transfer price as the arm's length price. Then to make a comparison of a horizontal item without segregation would

LG ELECTRONICS INDIA PRIVATE LIMITED,MATHURA ROAD, NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

transfer price as the arm's length price. Then to make a comparison of a horizontal item without segregation would