DCIT, CIRCLE- 1, LTU, NEW DELHI vs. THE ORIENTAL INSURANCE CO. LTD., NEW DELHI

Bench: Sh. Anil Chaturvedi & Sh.Anubhav Sharmaita No. 1952/Del/2018, A.Y. 2013-14 M/S. The Oriental Insurance Co. Vs. Dcit, Ltd. Circle-1, Ltu, A-25/27, Asaf Ali Road, New Delhi New Delhi- 110002 Pan :Aaact0627R

38) of the Act. 17. Even otherwise, the issue about applicability of provisions of section 10 of the Act in case of general insurance company stands decided in favor of insurance business companies and relevant observation in Max New York Life Insurance Co. Ltd V. DCIT 191 TTJ 897(Del) are as follows:- “97. Now coming to the additional ground

M/S THE ORIENTAL INSSURANCE CO.LTD.,,NEW DELHI vs. DCIT, NEW DELHI

Bench: Shri Anil Chaturvedi & Shri Anubhav Sharmam/S. The Oriental Insurance Co. Ltd, Vs. The Dcit, A 25/27, Asaf Ali Road, Ltu, New Delhi New Delhi-110002 (Appellant) (Respondent) Pan: Aaact0627R

38) of the Act. 17. Even otherwise, the issue about applicability of provisions of section 10 of the Act in case of general insurance company stands decided in favor of insurance business companies and relevant observation in Max New York Life Insurance Co. Ltd V. DCIT 191 TTJ 897(Del) are as follows:- “97. Now coming to the additional ground

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

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

38,06,61,370. 10. Aggrieved by the aforementioned draft assessment order, the Assessee filed objections before the Dispute Resolution Panel (‘DRP’) under Section 144-C (2) of the Act. By its order dated 23rd September 2011, the DRP upheld the addition made by the TPO on account of AMP expenses. 11. The AO completed the assessment in terms

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

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

38,06,61,370. 10. Aggrieved by the aforementioned draft assessment order, the Assessee filed objections before the Dispute Resolution Panel (‘DRP’) under Section 144-C (2) of the Act. By its order dated 23rd September 2011, the DRP upheld the addition made by the TPO on account of AMP expenses. 11. The AO completed the assessment in terms

MANKIND PHARMA LIMITED,DELHI vs. DCIT, CIRCLE-1(1)(1), MEERUT

In the result, the additional Ground No

Bench: Shri Challa Nagendra Prasad & Shri Pradip Kumar Kedia

10) r.w. Section 92BA of the Act is wholly unwarranted and consequently the adjustment made under transfer pricing provisions in the final assessment order is contrary to the position of law and factual matrix and thus requires to be reversed. 38

ECOENERGY INSIGHTS LTD ( FORMERLY KNOWN AS CHUBB ALBA CONTROL SYSTEMS P.LTD),NEW DELHI vs. DCIT, CIRCLE-4(2), NEW DELHI

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

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaecoenergy Insights Ltd., Vs. Dcit, (Formerly Known As Chubb Alba Control Circle 4 (2), Systems P. Ltd.), New Delhi. Ground Floor, 18, Netaji Subhash Marg, Daryaganj, New Delhi – 110 002. (Pan :Aaaca0031C) (Appellant) (Respondent) Assessee By : Shri Nageshwar Rao, Advocate Shri Parth, Advocate Shri Pratik Rath, Advocate Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 12.08.2025 Date Of Order : 10.11.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Assessment Order Dated 25.07.2022Passed By The Assessment Unit, Income Tax Department Under Section 147 Read With Section 144C(13) R.W.S. 144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Ay 2018-19 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act.

10. Section 92CA(1) of the Act empowers the Assessing Officer to make reference to TPO for the computation of arm's length price of international transactions. Further, the TPO as defined in explanation to section 92CA to be the person authorized by board to perform functions of AO specified in section 92C. In sub-section 3 of section 144B

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 Officer (“TPO”) by the Ld. AO in view of the fact that the transaction entered by the assessee with Adobe Systems India Pvt. Ltd. (“Adobe India”) has always been accepted at Arm’s Length Price (“ALP”) by the preceding TPO(s). 3.1 During the course of assessment proceedings the Ld. AO issued show cause notice

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

Section 92F (v), an international transaction could include an arrangement, understanding or action in concert, this cannot be a matter of inference. There has to be some tangible evidence on record to show that two parties have "acted in concert". XXX XXX XXX 37. The provisions under Chapter X do envisage a 'separate entity concept'. In other words, there cannot

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

Section 92F (v), an international transaction could include an arrangement, understanding or action in concert, this cannot be a matter of inference. There has to be some tangible evidence on record to show that two parties have "acted in concert". XXX XXX XXX 37. The provisions under Chapter X do envisage a 'separate entity concept'. In other words, there cannot

INCOME TAX OFFICER, DELHI vs. MEGHA GARG, DELHI

In the result, the appeal filed by the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2013-14] Income Tax Officer, Megha Garg, 1707 E-2 Block Civic Centre, 160 Saraswati Vihar Vaishali, New Delhi-110002 Vs Pitampura, Delhi-110034 Pan-Aecpg7098C Appellant Respondent

transfer of long term securities (Share dealings) - Assessment year 2013-14 - Assessee had sold shares of SNCFL and earned long- term capital gains - Assessing Officer issued a show cause notice alleging that transaction was a penny stock deal aimed at illegitimately claiming long-term capital gain exemption under section 10(38) - Assessing Officer treated purchase as bogus and added

VANEET AGGARWAL,NEW DELHI vs. ACIT, CIRCLE-14(2), NEW DELHI

In the result, appeal filed by the assessee is allowed

10(38), In view of fact\nthat purchase transaction of said shares was not recorded In stock exchange\nand, moreover, selling rates were artificially hiked later on with no real\nbuyers, Assessing Officer rightly rejected assessee's claim and added amount\nin question to his taxable income under section 88,\n\n17. Vinay Kumar Dhingra (HUF) New Delhi

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

Bench: Shri G. S. Pannu & Shri Yogesh Kumar U.S.I.T.A. No. 1976/Del/2020 (A.Y 2013-14)

transferred to various units including the units eligible for deduction u/s 80 IB/80 IC of the act based upon the sales ratio of all manufacturing units. 4. During assessment year 2005 – 06 to 2011 – 12 assessment orders were passed under the provisions of Section 153A/143 (3) of the Act based upon search and seizure operations carried out under the provisions

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

10 years. 10. Neither the certificates issued by Greater Noida Industrial Development Authority nor the Notification issued by the State Govt. authorises the assessee to collect sales tax from its customers. The assessee has been exempted from collecting the sales tax from customers on the sales made with effect from 27th March, 1998. In fact, the ld. counsel

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

10 years. 10. Neither the certificates issued by Greater Noida Industrial Development Authority nor the Notification issued by the State Govt. authorises the assessee to collect sales tax from its customers. The assessee has been exempted from collecting the sales tax from customers on the sales made with effect from 27th March, 1998. In fact, the ld. counsel

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

10 years. 10. Neither the certificates issued by Greater Noida Industrial Development Authority nor the Notification issued by the State Govt. authorises the assessee to collect sales tax from its customers. The assessee has been exempted from collecting the sales tax from customers on the sales made with effect from 27th March, 1998. In fact, the ld. counsel

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

10 years. 10. Neither the certificates issued by Greater Noida Industrial Development Authority nor the Notification issued by the State Govt. authorises the assessee to collect sales tax from its customers. The assessee has been exempted from collecting the sales tax from customers on the sales made with effect from 27th March, 1998. In fact, the ld. counsel

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

10 years. 10. Neither the certificates issued by Greater Noida Industrial Development Authority nor the Notification issued by the State Govt. authorises the assessee to collect sales tax from its customers. The assessee has been exempted from collecting the sales tax from customers on the sales made with effect from 27th March, 1998. In fact, the ld. counsel

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

10 years. 10. Neither the certificates issued by Greater Noida Industrial Development Authority nor the Notification issued by the State Govt. authorises the assessee to collect sales tax from its customers. The assessee has been exempted from collecting the sales tax from customers on the sales made with effect from 27th March, 1998. In fact, the ld. counsel