M/S. BG EXPLORATION & PRODUCTION INDIA LTD.,MUMBAI vs. JCIT, DEHRADUN

Bench: Shri I. C. Sudhir & Shri Prashant Maharishibg Exploration & Production Jcit, India Ltd, International Taxation, Bg House, Dehradun Vs. Lake Boulevard Road, Hiranandani Business Park, Powai, Mumbai Pan:Aaace4569K (Appellant) (Respondent) Dcit, Bg Exploration & Production International Taxation, India Ltd, Bg House, Lake Dehradun Boulevard Road, Hiranandani Vs. Business Park, Powai, Mumbai Pan: Aaace4569K (Appellant) (Respondent)

Transfer Pricing Officer has already determined the arm‘s length price of the international transactions amounting to Rs. 801326640/- as nil, no further separate addition was made by the Ld. Assessing Officer as it will amount to double disallowance. 11. Further during the year the Assessee has claimed exploration costs relating to contract areas other than on the account

MCKINSEY KNOWLEDGE CENTRE INDIA PVT. LTD.,GURGAON vs. DCIT, NEW DELHI

In the result ground No. 14 of the appeal of the assessee is dismissed

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishimckinsey Knowledge Centre India Pvt. Vs. Dcit, Ltd, Circle-16(2) 3Rd Floor, Block-Iii, Vatika Business Park, New Delhi Sector-49, Sohna Road, Gurgaon Pan:Aaccm2356G (Appellant) (Respondent)

Block-III, Vatika Business Park, New Delhi Sector-49, Sohna Road, Gurgaon PAN:AACCM2356G (Appellant) (Respondent) Assessee by : Shri Porus Kaka, Senior Advocate Shri Dinesh Chawla, Adv Revenue by: Shri Amrendra Kumar, CIT DR Date of Hearing 19/04/2017 Date of pronouncement 11/05/2017 O R D E R PER PRASHANT MAHARISHI, A. M. 1. This is an appeal filed

RANBAXY LABORATORIES LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, we direct the AO to reduce the book profit u/s 115JB of the Act by the amount of reversal of the provision of Rs

Bench: Sh. I. C.Sudhir Judicialmember & Sh. Prashant Maharishia.Y.: - 2008-09 Ranbaxy Laboratories Ltd. Vs Acit 12Th Floor, Devika Tower, Range -15 6, Nehru Place New Delhi New Delhi Pan No. Aaacr0127N (Appellant) (Respondent)

assesse that how disallowance already offered by assesse of Rs.3311708/- which are also certified by the tax auditor is incorrect. In absence of such satisfaction AO does not have any authority to invoke provisions of Rule 8D. On this count also the addition cannot be upheld. Honourable Delhi high court in case of CIT V TaikishaEngineering Limited in 54 taxmann.com

STERIA INDIA LTD.,NOIDA vs. ADDL.CIT, SPECIAQL RANGE-8, NEW DELHI

In the result ITA number 5745/del/2018 for assessment year 2014 – 15

Bench: Shri Kuldip Singh & Shri Prashant Maharishi

price of the international transaction of IT services was determined by selecting 14 comparable companies whose average profit level indicator was 16.89%. Against this assessee is in appeal before us. 63. The first contention of the assessee is that there is an incorrect computation of operating profit margin of the assessee as foreign exchange income amounting

M/S STERIA NDIA LTD.,,NOIDA vs. ADDL CIT, NEW DELHI

In the result ITA number 5745/del/2018 for assessment year 2014 – 15

Bench: Shri Kuldip Singh & Shri Prashant Maharishi

price of the international transaction of IT services was determined by selecting 14 comparable companies whose average profit level indicator was 16.89%. Against this assessee is in appeal before us. 63. The first contention of the assessee is that there is an incorrect computation of operating profit margin of the assessee as foreign exchange income amounting

STERIA (INDIA) LTD.,NOIDA vs. ADDL. CIT, SPL. RANGE- 8 , NEW DELHI

In the result ITA number 5745/del/2018 for assessment year 2014 – 15

Bench: Shri Kuldip Singh & Shri Prashant Maharishi

price of the international transaction of IT services was determined by selecting 14 comparable companies whose average profit level indicator was 16.89%. Against this assessee is in appeal before us. 63. The first contention of the assessee is that there is an incorrect computation of operating profit margin of the assessee as foreign exchange income amounting

THE COMMISSIONER OF INCOME TAX vs. M.S.AGGARWAL

transfer should be voluntary and should be made without consideration of any money.‖ 39. At this stage, we may also refer to the observations of the Delhi High Court in the case of CIT Vs. Sunita Vacchani 184 ITR 121 as refereed by the Id. Counsel. The Hon‘ble high Court observed, ―The Tribunal has examined the evidence which

AMERICAN EXPRESS (INDIA) PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

The appeal of the assessee is partly allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishiamerican Express (India) Pvt. Ltd, Vs. Dcit, Metropolitan Saket, 7Th Floor, Circle-2(2), Office Block, District Centre, New Delhi Saket, New Delhi Pan:Aaaca8163F (Appellant) (Respondent) Dcit, Vs. American Express (India) Pvt. Circle-2(2), Ltd, New Delhi Metropolitan Saket, 7Th Floor, Office Block, District Centre, Saket, New Delhi Pan: Aaaca8163F (Appellant) (Respondent)

Block, District Centre, Saket, New Delhi PAN: AAACA8163F (Appellant) (Respondent) Assessee by : Shri Nageswar Rao, Adv Revenue by: Shri TM Shivakumar, CIT DR Date of Hearing 28/03/2017 Date of pronouncement 07/06/2017 O R D E R PER PRASHANT MAHARISHI, A. M. American Express ( India ) Private Limited V DCIT ITA No 1868/del/2015 DCIT V American express ( India) Private Limited

AMERICA EXPRESS SERVICES INDIA LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, both the appeals filed by the assessee are allowed for

Bench: Shri Shamim Yahya & Shri Anubhav Sharma

Block, District Centre, Saket, New Delhi – 110 017. (PAN : AABCT0555T) (APPELLANT) (RESPONDENT) ASSESSEE BY : Shri Nageshwar Rao, Advocate Ms. Viyushti Rawat, Advocate REVENUE BY : Shri Rajesh Kumar, CIT DR Shri Manu Chaurasia, Sr. DR Date of Hearing : 02.01.2024 Date of Order : 09.01.2024 ORDER PER SHAMIM YAHYA, ACCOUNTANT MEMBER : The aforesaid appeals filed by the assessee are directed against the respective

M/S. AMERICAN EXPRESS SERVICES INDIA LIMITED,NEW DELHI vs. DCIT, NEW DELHI

In the result, both the appeals filed by the assessee are allowed for

Bench: Shri Shamim Yahya & Shri Anubhav Sharma

Block, District Centre, Saket, New Delhi – 110 017. (PAN : AABCT0555T) (APPELLANT) (RESPONDENT) ASSESSEE BY : Shri Nageshwar Rao, Advocate Ms. Viyushti Rawat, Advocate REVENUE BY : Shri Rajesh Kumar, CIT DR Shri Manu Chaurasia, Sr. DR Date of Hearing : 02.01.2024 Date of Order : 09.01.2024 ORDER PER SHAMIM YAHYA, ACCOUNTANT MEMBER : The aforesaid appeals filed by the assessee are directed against the respective

BLACKROCK SERVICES INDIA PRIVATE LIMITED,GURGAON vs. INCOME TAX OFFICER, GURGAON

The appeal of the assessee is allowed

Bench: Shri H. S. Sidhu & Shri Prashant Maharishiblack Rock Services India Private Vs. The Income Tax Officer, 5Th Floor, Hsidc Building Vanijya Limited, 3Rd Floor, Rolta Corporate Towers, 187, Nikunj, Udyog Vihar, Phase-V, Phase-I, Udyog Vihar, Gurgaon Gurgaon Pan: Aabch4449Q (Appellant) (Respondent) Black Rock Services India Private The Assistant Commissioner Of Vs. Limited, Income Tax , 3Rd Floor, Rolta Corporate Towers, 187, Circle-1(1), Phase-I, Udyog Vihar, Gurgaon Gurgaon Pan: Aabch4449Q (Appellant) (Respondent)

assesses. Therefore he submitted that those comparables should also be excluded from the comparability analysis in case of the international transactions of the assessee also. We will deal with each of the comparable independently looking into their functionality and comparing it with the functionality of the assessee. 8. The learned departmental representative also vehemently objected to the argument

BLACKROCK SERVICES INDIA PVT. LTD.,GURGAON vs. ACIT, GURGAON

The appeal of the assessee is allowed

Bench: Shri H. S. Sidhu & Shri Prashant Maharishiblack Rock Services India Private Vs. The Income Tax Officer, 5Th Floor, Hsidc Building Vanijya Limited, 3Rd Floor, Rolta Corporate Towers, 187, Nikunj, Udyog Vihar, Phase-V, Phase-I, Udyog Vihar, Gurgaon Gurgaon Pan: Aabch4449Q (Appellant) (Respondent) Black Rock Services India Private The Assistant Commissioner Of Vs. Limited, Income Tax , 3Rd Floor, Rolta Corporate Towers, 187, Circle-1(1), Phase-I, Udyog Vihar, Gurgaon Gurgaon Pan: Aabch4449Q (Appellant) (Respondent)

assesses. Therefore he submitted that those comparables should also be excluded from the comparability analysis in case of the international transactions of the assessee also. We will deal with each of the comparable independently looking into their functionality and comparing it with the functionality of the assessee. 8. The learned departmental representative also vehemently objected to the argument

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

In the result, the appeal of the assessee is partly allowed and that of

Bench: Shri R.S. Syal & Shri Kuldip Singhassessment Year : 2004-05

transfer pricing grounds in these cross appeals. Ground nos. 24-27 of the assessee’s appeal and one additional ground taken by the assessee assail the sustenance of addition on account of Provision for doubtful debts and Provision for doubtful advances. During the course of assessment proceedings, it was noticed by the AO that the assessee made Provision for doubtful

M/S. SWARO vs. KI INDIA PRIVATE LIMITED,NEW DELHIVS.ACIT, NEW DELHI

In the result, the appeal of the assessee is partly allowed and that of

Bench: Shri R.S. Syal & Shri Kuldip Singhassessment Year : 2004-05

transfer pricing grounds in these cross appeals. Ground nos. 24-27 of the assessee’s appeal and one additional ground taken by the assessee assail the sustenance of addition on account of Provision for doubtful debts and Provision for doubtful advances. During the course of assessment proceedings, it was noticed by the AO that the assessee made Provision for doubtful

DDIT, DEHRADUN vs. BG EXPLORATION & PRODUCTION INDIA LTD., MUMBAI

In the result ground No. 2 of the appeal of the assessee is dismissed

Bench: Shri I. C. Sudhir & Shri Prashant Maharishidy. Director Of Income Tax, Bg Exploration & Production India International Taxation, Ltd, Dehradun Bg House, Vs. Lake Boulevard Road, Hiranandani Business Park, Powai, Mumbai Pan: Aaace4569K (Appellant) (Respondent)

price of the services which is been received by the assessee at nil. In view of this we uphold the finding of the Ld. Dispute Resolution Panel holding that transactions of intragroup services are interlinked, therefore, they should be benchmarked together by adopting TNMM as the most appropriate method , hence, directing the Ld. transfer pricing officer to delete the adjustment

ACIT, FARIDABAD vs. M/S. BCEOM (INDIA) P. LTD., FARIDABAD

In the result appeal filed by the learned assessing officer for assessment year 2010 – 11 in ITA No

Bench: Shri H.S.Sidhu & Shri Prashant Maharishi

Block I-B, (Now known as Egis India Faridabad Consulting Engineers Pvt. Ltd), 12/6, Saffron Square, Delhi Mathura Road, Faridabad PAN: AACCB6390F (Appellant) (Respondent) ITA No. 583/Del/2014 & 6152/Del/2015 (Assessment Year: 2008-09 and 2010-11) DCIT, Vs. M/s. BCEOM (India)P. Ltd, Circle-I, Faridabad (Now known as Egis India Consulting Engineers Pvt. Ltd), 12/6, Saffron Square, Delhi Mathura Road

DCIT, FARIDABAD vs. M/S. BCEOM (INDIA) PVT. LTD., FARIDABAD

In the result appeal filed by the learned assessing officer for assessment year 2010 – 11 in ITA No

Bench: Shri H.S.Sidhu & Shri Prashant Maharishi

Block I-B, (Now known as Egis India Faridabad Consulting Engineers Pvt. Ltd), 12/6, Saffron Square, Delhi Mathura Road, Faridabad PAN: AACCB6390F (Appellant) (Respondent) ITA No. 583/Del/2014 & 6152/Del/2015 (Assessment Year: 2008-09 and 2010-11) DCIT, Vs. M/s. BCEOM (India)P. Ltd, Circle-I, Faridabad (Now known as Egis India Consulting Engineers Pvt. Ltd), 12/6, Saffron Square, Delhi Mathura Road

ACIT, FARIDABAD vs. M/S. BCEOM (INDIA) P. LTD., FARIDABAD

In the result appeal filed by the learned assessing officer for assessment year 2010 – 11 in ITA No

Bench: Shri H.S.Sidhu & Shri Prashant Maharishi

Block I-B, (Now known as Egis India Faridabad Consulting Engineers Pvt. Ltd), 12/6, Saffron Square, Delhi Mathura Road, Faridabad PAN: AACCB6390F (Appellant) (Respondent) ITA No. 583/Del/2014 & 6152/Del/2015 (Assessment Year: 2008-09 and 2010-11) DCIT, Vs. M/s. BCEOM (India)P. Ltd, Circle-I, Faridabad (Now known as Egis India Consulting Engineers Pvt. Ltd), 12/6, Saffron Square, Delhi Mathura Road