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

exemption of sales tax to the extent of exemption or reduction in tax. Item (2) of the Schedule includes Greater Noida Industrial Development Area wherein exemption from sales tax to the extent of 200 per cent of capital investment has been provided. None of the clauses of the Notification authorises the assessee to collect the sales tax and retain

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

exemption of sales tax to the extent of exemption or reduction in tax. Item (2) of the Schedule includes Greater Noida Industrial Development Area wherein exemption from sales tax to the extent of 200 per cent of capital investment has been provided. None of the clauses of the Notification authorises the assessee to collect the sales tax and retain

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

exemption of sales tax to the extent of exemption or reduction in tax. Item (2) of the Schedule includes Greater Noida Industrial Development Area wherein exemption from sales tax to the extent of 200 per cent of capital investment has been provided. None of the clauses of the Notification authorises the assessee to collect the sales tax and retain

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

exemption of sales tax to the extent of exemption or reduction in tax. Item (2) of the Schedule includes Greater Noida Industrial Development Area wherein exemption from sales tax to the extent of 200 per cent of capital investment has been provided. None of the clauses of the Notification authorises the assessee to collect the sales tax and retain

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

exemption of sales tax to the extent of exemption or reduction in tax. Item (2) of the Schedule includes Greater Noida Industrial Development Area wherein exemption from sales tax to the extent of 200 per cent of capital investment has been provided. None of the clauses of the Notification authorises the assessee to collect the sales tax and retain

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

exemption of sales tax to the extent of exemption or reduction in tax. Item (2) of the Schedule includes Greater Noida Industrial Development Area wherein exemption from sales tax to the extent of 200 per cent of capital investment has been provided. None of the clauses of the Notification authorises the assessee to collect the sales tax and retain

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

exemption of sales tax to the extent of exemption or reduction in tax. Item (2) of the Schedule includes Greater Noida Industrial Development Area wherein exemption from sales tax to the extent of 200 per cent of capital investment has been provided. None of the clauses of the Notification authorises the assessee to collect the sales tax and retain

DCIT, CC-29, NEW DELHI vs. DHARAMPAL SATYALPAL LTD., NEW DELHI

Bench: Shri G. S. Pannu & Shri Yogesh Kumar U.S.I.T.A. No. 1977/Del/2020 (A.Y 2014-15)

transfer but subscribe actual earning of profit, then impugned suggestion of AO do not have legal sanctity in eyes of law. 10.09 A very pertinent question has been raised by Id.AR Mr. Patel that what should be line of demarcation to determine sale price of a product if not market DCIT Vs. Dharampal Satyapal Ltd. price. As far as present

DCM SHRIRAM LTD,NEW DELHI vs. ACIT, CIRCLE-7(1), NEW DELHI

transfer pricing\nadjustment to the extent of deduction u/s 80-IA of the Act claimed by\nrespective eligible power units of the assessee and thereby making an\nexcess disallowance to the tune of Rs.40,65,76,101/-.\nGROUNDS OF OBJECTIONS AGAINST CORPORATE TAX\nDISALLOWANCES\nAdditional Disallowance u/s 14A of Rs.4,14,870/-\n6. The Ld. DRP/AO has erred

DCM SHRIRAM LIMITED,DELHI vs. ASSESSMENT UNIT, DELHI

transfer pricing\nadjustment to the extent of deduction u/s 80-IA of the Act claimed by\nrespective eligible power units of the assessee and thereby making an\nexcess disallowance to the tune of Rs.40,65,76,101/-.\nGROUNDS OF OBJECTIONS AGAINST CORPORATE TAX\nDISALLOWANCES\nAdditional Disallowance u/s 14A of Rs.4,14,870/- \n6. The Ld. DRP/AO has erred

DCIT, NEW DELHI vs. DCM SHRIRAM LTD, NEW DELHI

transfer pricing\nadjustment to the extent of deduction u/s 80-IA of the Act claimed by\nrespective eligible power units of the assessee and thereby making an\nexcess disallowance to the tune of Rs.40,65,76,101/-.\n\nGROUNDS OF OBJECTIONS AGAINST CORPORATE TAX\nDISALLOWANCES\n\nAdditional Disallowance u/s 14A of Rs.4,14,870/-\n\n6. The Ld. DRP/AO

DCM SHRIIRAM LIMITED,NEW DELHI vs. NEAC, NEW DELHI

transfer pricing\nadjustment to the extent of deduction u/s 80-IA of the Act claimed by\nrespective eligible power units of the assessee and thereby making an\nexcess disallowance to the tune of Rs.40,65,76,101/-.\n\nGROUNDS OF OBJECTIONS AGAINST CORPORATE TAX\nDISALLOWANCES\n\nAdditional Disallowance u/s 14A of Rs.4,14,870/- \n\n6. The Ld. DRP/AO

HEWITT ASSOCIATES (INDIA) PVT. LTD.,GURGAON vs. ACIT, NEW DELHI

In the result, the appeal of the assesee is treated as allowed for statistical purposes

Bench: Shri R.K. Panda & Ms. Astha Chandraasstt. Year : 2007-08

transfer price. 9 2.12 By not allowing the benefit of (+/-) 5% as provided in the proviso to Section 92C (2) of the Act, while determining the arm's length price of the international transactions of the Appellant. 2.13 By not appreciating that there was no intention whatsoever on the part of the Appellant to shift profits outside India by under

SONY INDIA PRIVATE LIMITED,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME-TAX, NEW DELHI

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

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Transfer Pricing, rule is to benchmark transactions by transactions. Only if the transactions are closely linked, then the same can be aggregated, but aggregation is more of exception, than a rule. If the Hon’ble jurisdiction High Court in the case of Sony Ericsson has held that AMP is the separate international transaction specially in the case of distribution companies

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

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

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Transfer Pricing, rule is to benchmark transactions by transactions. Only if the transactions are closely linked, then the same can be aggregated, but aggregation is more of exception, than a rule. If the Hon’ble jurisdiction High Court in the case of Sony Ericsson has held that AMP is the separate international transaction specially in the case of distribution companies

SRF LIMITED,DELHI vs. ASSISTANT / DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 10(1), NEW DELHI, DELHI

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

price of steam transferred by CPP unit at Dahej, Gujarat to Rs. 1,42,57,52,588/- [instead of Rs. 55,15,74,973/-] which is computed by multiplying the equivalent quantity of such steam in terms of unit of electricity (KwH) as certified by the Chartered Engineer with the ALP rate of electricity in accordance with the directions

SRF LIMITED,NEW DELHI vs. ACIT, CIRCLE-10(1), DELHI

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

price of steam transferred by CPP unit at Dahej, Gujarat to Rs. 1,42,57,52,588/- [instead of Rs. 55,15,74,973/-] which is computed by multiplying the equivalent quantity of such steam in terms of unit of electricity (KwH) as certified by the Chartered Engineer with the ALP rate of electricity in accordance with the directions

SRF LIMITED ,DELHI vs. ACIT, CIRCLE-10(1), DELHI

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

price of steam transferred by CPP unit at Dahej, Gujarat to Rs. 1,42,57,52,588/- [instead of Rs. 55,15,74,973/-] which is computed by multiplying the equivalent quantity of such steam in terms of unit of electricity (KwH) as certified by the Chartered Engineer with the ALP rate of electricity in accordance with the directions