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

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

reassessment orders passed by the Ld. AO after the pronouncement of the decision of the Hon’ble Supreme Court in the case of Engineering Analysis Centre of Excellence Private Limited (supra) i.e. for AY 2016-17, AY 2017-18, AY 2018-19, AY 2019- 20 and AY 2020-21, the Ld. AO has not alleged that the receipts

ADOBE SYSTEMS SOFTWERE IRELAND LIMITED,DUBLIN 24, IRELAND vs. DCIT CIRCLE- 1(1)(1), INTERNATIONAL TAXATION , NEW DELHI

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

reassessment orders passed by the Ld. AO after the pronouncement of the decision of the Hon’ble Supreme Court in the case of Engineering Analysis Centre of Excellence Private Limited (supra) i.e. for AY 2016-17, AY 2017-18, AY 2018-19, AY 2019- 20 and AY 2020-21, the Ld. AO has not alleged that the receipts

DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., DUBLIN, IRELAND

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

reassessment orders passed by the Ld. AO after the pronouncement of the decision of the Hon’ble Supreme Court in the case of Engineering Analysis Centre of Excellence Private Limited (supra) i.e. for AY 2016-17, AY 2017-18, AY 2018-19, AY 2019- 20 and AY 2020-21, the Ld. AO has not alleged that the receipts

DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., NEW DELHI

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

reassessment orders passed by the Ld. AO after the pronouncement of the decision of the Hon’ble Supreme Court in the case of Engineering Analysis Centre of Excellence Private Limited (supra) i.e. for AY 2016-17, AY 2017-18, AY 2018-19, AY 2019- 20 and AY 2020-21, the Ld. AO has not alleged that the receipts

ADOBE SYSTEMS SOFTWARE IRELAND LTD.,DUBLIN, IRELAND vs. DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

reassessment orders passed by the Ld. AO after the pronouncement of the decision of the Hon’ble Supreme Court in the case of Engineering Analysis Centre of Excellence Private Limited (supra) i.e. for AY 2016-17, AY 2017-18, AY 2018-19, AY 2019- 20 and AY 2020-21, the Ld. AO has not alleged that the receipts

DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., DUBLIN, IRELAND

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

reassessment orders passed by the Ld. AO after the pronouncement of the decision of the Hon’ble Supreme Court in the case of Engineering Analysis Centre of Excellence Private Limited (supra) i.e. for AY 2016-17, AY 2017-18, AY 2018-19, AY 2019- 20 and AY 2020-21, the Ld. AO has not alleged that the receipts

DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., DUBLIN, IRELAND

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

reassessment orders passed by the Ld. AO after the pronouncement of the decision of the Hon’ble Supreme Court in the case of Engineering Analysis Centre of Excellence Private Limited (supra) i.e. for AY 2016-17, AY 2017-18, AY 2018-19, AY 2019- 20 and AY 2020-21, the Ld. AO has not alleged that the receipts

DCIT, CIRCLE- 1(1)(1), INTERNATIONAL TAXATION, NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., NEW DELHI

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

reassessment orders passed by the Ld. AO after the pronouncement of the decision of the Hon’ble Supreme Court in the case of Engineering Analysis Centre of Excellence Private Limited (supra) i.e. for AY 2016-17, AY 2017-18, AY 2018-19, AY 2019- 20 and AY 2020-21, the Ld. AO has not alleged that the receipts

DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., DUBLIN, IRELAND

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

reassessment orders passed by the Ld. AO after the pronouncement of the decision of the Hon’ble Supreme Court in the case of Engineering Analysis Centre of Excellence Private Limited (supra) i.e. for AY 2016-17, AY 2017-18, AY 2018-19, AY 2019- 20 and AY 2020-21, the Ld. AO has not alleged that the receipts

DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., DUBLIN, IRELAND

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

reassessment orders passed by the Ld. AO after the pronouncement of the decision of the Hon’ble Supreme Court in the case of Engineering Analysis Centre of Excellence Private Limited (supra) i.e. for AY 2016-17, AY 2017-18, AY 2018-19, AY 2019- 20 and AY 2020-21, the Ld. AO has not alleged that the receipts

ADOBE SYSTEMS SOFTWARE IRELAND LTD.,DUBLIN, IRELAND vs. DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

reassessment orders passed by the Ld. AO after the pronouncement of the decision of the Hon’ble Supreme Court in the case of Engineering Analysis Centre of Excellence Private Limited (supra) i.e. for AY 2016-17, AY 2017-18, AY 2018-19, AY 2019- 20 and AY 2020-21, the Ld. AO has not alleged that the receipts

DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., DUBLIN, IRELAND

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

reassessment orders passed by the Ld. AO after the pronouncement of the decision of the Hon’ble Supreme Court in the case of Engineering Analysis Centre of Excellence Private Limited (supra) i.e. for AY 2016-17, AY 2017-18, AY 2018-19, AY 2019- 20 and AY 2020-21, the Ld. AO has not alleged that the receipts

ADOBE SYSTEMS SOFTWARE IRELAND LTD.,IRELAND vs. DCIT, CIRCLE- 1(1)(1), INTERNATIONAL TAXATION, NEW DELHI

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

reassessment orders passed by the Ld. AO after the pronouncement of the decision of the Hon’ble Supreme Court in the case of Engineering Analysis Centre of Excellence Private Limited (supra) i.e. for AY 2016-17, AY 2017-18, AY 2018-19, AY 2019- 20 and AY 2020-21, the Ld. AO has not alleged that the receipts

DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., DUBLIN, IRELAND

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

reassessment orders passed by the Ld. AO after the pronouncement of the decision of the Hon’ble Supreme Court in the case of Engineering Analysis Centre of Excellence Private Limited (supra) i.e. for AY 2016-17, AY 2017-18, AY 2018-19, AY 2019- 20 and AY 2020-21, the Ld. AO has not alleged that the receipts

ADOBE SYSTEMS SOFTWARE IRELAND LTD.,IRELAND vs. DCIT, CIRCLE- 1(1)(1), INTERNATIONAL TAXATION, NEW DELHI

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

reassessment orders passed by the Ld. AO after the pronouncement of the decision of the Hon’ble Supreme Court in the case of Engineering Analysis Centre of Excellence Private Limited (supra) i.e. for AY 2016-17, AY 2017-18, AY 2018-19, AY 2019- 20 and AY 2020-21, the Ld. AO has not alleged that the receipts

ADOBE SYSTEMS SOFTWARE IRELAND LTD.,IRELAND vs. DCIT, CIRCLE- 1(1)(1), INTERNATIONAL TAXATION, NEW DELHI

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

reassessment orders passed by the Ld. AO after the pronouncement of the decision of the Hon’ble Supreme Court in the case of Engineering Analysis Centre of Excellence Private Limited (supra) i.e. for AY 2016-17, AY 2017-18, AY 2018-19, AY 2019- 20 and AY 2020-21, the Ld. AO has not alleged that the receipts

THE PR. COMMISSIONER OF INCOME TAX -4 vs. HEADSTRONG SERVICES INDIA PVT. LTD.

Transfer Pricing Officer before the said date, or a reference under subsection (1) is made on or after the 1st day of June, 2007, an order under sub-section (3) may be made at any time before sixty days prior to the date on which the period of limitation referred to in section 153, or as the case

RAMPGREEN SOLUTIONS PVT LTD vs. COMMISSIONER OF INCOME TAX

The appeal is allowed

Bench: The Tribunal, Impugning The Assessment Order Passed By The Assessing Officer (Hereafter ‘Ao’) Making The Transfer Pricing Adjustments (Hereafter ‘Tp Adjustments’) In Respect Of The Assessment Year (Hereafter ‘Ay’) 2008-09 As Finalised By The Transfer Pricing Officer 2015:Dhc:6421-Db

transfer of income to a jurisdiction outside India, if any, in respect of the controlled transactions. 15. The exercise of determining the ALP in respect of international transactions between the related enterprises is aimed to determine the price, which would have been charged for products and services, as nearly as possible, in case such international transactions were not controlled