DCM SHRIIRAM LTD.,NEW DELHI vs. ADDL.CIT, SPECIAL RANGE- 3 , NEW DELHI

In the result appeal of assessee is partly allowed

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

transfer pricing additions / disallowances. 1.2 That the final assessment order u/s 143(3) r.w.s. 144C of the Act dated 31 October

NOBLE RESOURCE & TRADING INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

The appeal is allowed with above direction

Bench: Shri Amit Shukla & Shri Prashant Maharishi

transfer pricing adjustment was Rs. 78159764/-. Consequently, total income of assessee was assessed at loss of Rs. 13095662/– against the returned loss of Rs. 215212462/–. One corporate tax adjustment of Rs. 123957036/- was also made on account of disallowance

NOBLE RESOURCES & TRADING INDIA PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

The appeal is allowed with above direction

Bench: Shri Amit Shukla & Shri Prashant Maharishi

transfer pricing adjustment was Rs. 78159764/-. Consequently, total income of assessee was assessed at loss of Rs. 13095662/– against the returned loss of Rs. 215212462/–. One corporate tax adjustment of Rs. 123957036/- was also made on account of disallowance

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 determined the arm‘s length price at rupees Nil , the balance sum of Rs. 11374089/– was disallowed

(Now known as Sony India Limited)

transfer price. (c) The foreign parent provided the distributor with a rebate of a portion of the distributor's AMP expenditure based on sales volumes. Following the theories in the above Tax Court case, the cheese examples could require a return for the distributor investment in the marketing intangibles either in the form of a service fee arrangement with

LIUGONG INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

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

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

transfer pricing adjustments 26,65,36,577/- II. Disallowance u/s. 40(a)(ia) 84,88,503/- III. Disallowance u/s. 14A 1,308/- 4. During

CIT vs. CUSHMAN AND WAKEFIELD INDIA PVT LTD

The appeal is partly allowed

Transfer Pricing Officer has exceeded his jurisdiction by disallowing certain expenditure, is against the facts. The Transfer Pricing Officer has not disallowed

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)

disallowances, which are squarely covered in favour of assesse by appellate orders for earlier years in assessee‘s own case. This ground is general in nature and as against each addition/disallowances separate grounds are raised, therefore, this ground is not dealt with by the parties before us and hence, it is dismissed. Transfer pricing

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

Transfer Pricing Officer it upheld the same. 26. With respect to the corporate tax issues the learned Dispute Resolution Panel upheld the disallowance

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

Transfer Pricing Officer it upheld the same. 26. With respect to the corporate tax issues the learned Dispute Resolution Panel upheld the disallowance

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)

price, i.e., Rs. 69 crore. Keeping in view the observations of the Shunglu Committee report, the AO made various disallowances. 5. The ld. AR, in support of the deletion of the transfer

AMADEUS INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, ITA NO. 7691/Del/2017 stands allowed

Bench: Shri N.S. Saini & Shri Sudhanshu Srivastava

Transfer Pricing Adjustment of Rs.8,98,683/- on account of alleged transaction for notional interest on receivables. (c) Disallowance u/s 10A of the Act 2.3 The first

AMADEUS INDIA PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, ITA NO. 7691/Del/2017 stands allowed

Bench: Shri N.S. Saini & Shri Sudhanshu Srivastava

Transfer Pricing Adjustment of Rs.8,98,683/- on account of alleged transaction for notional interest on receivables. (c) Disallowance u/s 10A of the Act 2.3 The first

AMADEUS INDIA PVT. LTD.,NEW DELHI vs. ACIT, CIRCLE- 2(2), NEW DELHI

In the result, ITA NO. 7691/Del/2017 stands allowed

Bench: Shri N.S. Saini & Shri Sudhanshu Srivastava

Transfer Pricing Adjustment of Rs.8,98,683/- on account of alleged transaction for notional interest on receivables. (c) Disallowance u/s 10A of the Act 2.3 The first

BT E- SERV (INDIA) PVT. LTD.,NEW DELHI vs. ITO, NEW DELHI

In the result appeal No. 99/Del/2016 filed by the assessee for assessment year 2011 – 12 is partly allowed

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi & Bt E-Serv (India) Pvt. Ltd, Ito, 11Th Floor, Eros Corporate Tower, Ward-5(2), Vs. Nehru Place, New Delhi New Delhi Pan:Aadcb2533M (Appellant) (Respondent)

disallowance of deduction on account of u/s 10AA of Rs. 29086105/- and addition on account of arms length price u/s 92CA(3) of Rs. 76391345/- was made as per the order of the ld Transfer

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)

Transfer Pricing Officer {hereinafter referred to as the “TPO”} had vide order dated 14th September 2011 accepted the ALP of all International Transactions undertaken by the appellant. 3.1 That on facts and in law the CIT(A) erred in upholding the addition on account of alleged “Transaction” / “International Transaction” of issue of Corporate Guarantee without appreciating that there

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)

Transfer Pricing Officer {hereinafter referred to as the “TPO”} had vide order dated 14th September 2011 accepted the ALP of all International Transactions undertaken by the appellant. 3.1 That on facts and in law the CIT(A) erred in upholding the addition on account of alleged “Transaction” / “International Transaction” of issue of Corporate Guarantee without appreciating that there

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)

disallowing the use of working capital adjustment to the appellant. 8. That the ld Ld. AO/Transfer Pricing Officer (Transfer Pricing