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)

viii. Graphite India Ltd [ITA Nos.304-305/Kol/2008 ix. Gujarat Fluor chemicals Ltd. [[2018] 97 taxmann.com 10 (Ahmadabad - Trib.)] x. Hero MotoCorp Limited [TS-844-ITAT-2012(Mum)] xi. Saf Yeast Company Pvt. Ltd. [TS-614-ITAT-2017(Mum)] vi. He further submitted that the rule 10 THC provides that the use of tariff notified by the electricity commission should be considered

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)

6) to ONGC and reliance seeking the above information was also not received. Therefore, the Ld. Transfer Pricing Officer determined the ALP in respect of the amount paid by the Assessee to its AE for various services amounting to Rs. 3329766244/– as nil. With respect to the joint acquisition of IT infrastructure and software cost

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)

Section (2) to Section 14A of the Act and sub Rule (1) to Rule 8D of the Rules. 14. The view and legal ratio expressed above is not being elucidated for the first time. The Delhi High Court in Maxopp Investment Ltd. v. CIT [2012] 347 ITR 272/203 Taxman 364/15 taxmann.com 390 has observed:- 'Scope of sub-sections

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

10 5693 173 CUP No 4 on sales adjustment proposed Interest on 6892 462 CUP 17335147 10442685/- 5 subordinate that is Share application 20 000000 CUP No 6 money adjustment ITA No 4249 / Del/2012, 4110/Del/2013 & 6337/Del/2013 A Y 2007-08 and 2008-09 Jindal Steel Limited Vs ACIT Cen Circle 4(1) , New Delhi proposed Reimbursement

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

10 5693 173 CUP No 4 on sales adjustment proposed Interest on 6892 462 CUP 17335147 10442685/- 5 subordinate that is Share application 20 000000 CUP No 6 money adjustment ITA No 4249 / Del/2012, 4110/Del/2013 & 6337/Del/2013 A Y 2007-08 and 2008-09 Jindal Steel Limited Vs ACIT Cen Circle 4(1) , New Delhi proposed Reimbursement

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

6 of appeal pertains to Transfer Pricing Adjustment on account of excessive AMP expenditure of Rs.114.89 crores. Briefly stated, the relevant facts in this regard are that the assessee M/s Amadeus India Pvt. Ltd. is an Indian Company whose share holding is as under:- M Bird Travels Private Limited Mrs. Radha Bhatia and Family (100% ownership with Mrs. Radha

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

6 of appeal pertains to Transfer Pricing Adjustment on account of excessive AMP expenditure of Rs.114.89 crores. Briefly stated, the relevant facts in this regard are that the assessee M/s Amadeus India Pvt. Ltd. is an Indian Company whose share holding is as under:- M Bird Travels Private Limited Mrs. Radha Bhatia and Family (100% ownership with Mrs. Radha

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

6 of appeal pertains to Transfer Pricing Adjustment on account of excessive AMP expenditure of Rs.114.89 crores. Briefly stated, the relevant facts in this regard are that the assessee M/s Amadeus India Pvt. Ltd. is an Indian Company whose share holding is as under:- M Bird Travels Private Limited Mrs. Radha Bhatia and Family (100% ownership with Mrs. Radha

YORK TECH PVT. LTD.,NEW DELHI vs. DCIT CIRCLE-25(1), NEW DELHI

The appeal of the assessee is allowed

Bench: Shri Amit Shukla & Dr. B.R.R. Kumar

Transfer Pricing Report. The ld. Assessing Officer sent a proposal to the PCIT, New Delhi to Additional CIT, Range-27 for seeking approval of I.T.A. No.635/DEL/2021 5 making reference to the TPO for determination of Arm’s Length Price as per the provision of Section 92BA r.w.s. 92C in respect of SDT with the holding company M/s. Uphill Farms

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

In the result, appeal of the assessee in ITA No

Bench: Shri N.K. Billaiya & Ms. Suchitra Kamble[A.Y 2014-15]

10,62,42,075 Rs 24,01,12,542 Rs 114,89,41,243 Cumulative addition Rs 101,50,70,775 2.8 Being aggrieved by the above proposed transfer pricing adjustment, the assessee filed detailed objections before the Ld. DRP. The Ld. DRP, while referring to decision of the Hon’ble Delhi High Court in the case of Sony Ericsson

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

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

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 of the directions

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

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

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 of the directions

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)

VIII. It is pertinent to note that provisions of section 80IA(8) read with section 80IB(13)/80IC(7) of The Act authorizes an assessing officer to make adjustments in claim of deduction by substituting fair market value of goods transferred from non-eligible unit to eligible unit, section specifically talks about market value that in itself means that product

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

In the result, the appeal of assessee are allowed

Bench: Sh. Anil Chaturvedi & Sh. Amit Shukla(Through Video Conferencing) Amadeus India Pvt. Ltd., Vs. Acit E-9, Connaught Hose, Circle – 2(2), Connaught Place, New Delhi New Delhi - 110001 Pan No. Aaaca 0364 L (Appellant) (Respondent) Assessee By Shri Taran Deep Singh, Adv. Revenue By Shri Surender Pal, Cit-D.R. Date Of Hearing: 18/05/2021 Date Of Pronouncement: 31/05/2021 Order Per Anil Chaturvedi, Am: This Appeal Filed By The Assessee Is Directed Against The Order Dated 19.09.2019 Of The Asst. Commissioner Of Income Tax, Circle-2(2), Delhi Under Section 143(3) R.W.S 144C(13) Of The Act Pursuant To The Direction Of Dispute Resolution Panel (Drp) – 1, Delhi For Assessment Year 2015-16. 2. The Relevant Facts As Culled From The Material On Records Are As Under :

6. Before us, at the outset, Learned AR submitted that though the assessee has raised various grounds in appeal but the sole issue in dispute pertains to the transfer of pricing adjustment on account of AMP expenses. 7. It was noticed that assessee had incurred expenditure on advertisement promotion, the details of which are as under: Particulars Amount

PR. COMMISSIONER OF INCOME TAX -7 vs. SUMITOMO CORPORATION INDIA (P) LTD.

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE RAVINDER DUDEJA

Transfer Pricing Officer is received by him.] (6) Nothing contained in sub-sections (1) [, (1-A)] and (2) shall apply to the following classes of assessments, reassessments and recomputation which may, subject to the provisions of [sub-sections (3), (5) and (5-A)], be completed— (i) where the assessment, reassessment or recomputation is made Digitally Signed By:KAMLESH KUMAR Signing

THE PR. COMMISSIONER OF INCOME TAX -6 vs. MICROSOFT INDIA ( R & D) PVT. LTD.

Bench: HON'BLE MR. JUSTICE VIPIN SANGHI,HON'BLE MR. JUSTICE SANJEEV NARULA

Transfer Pricing Officer is received by him.] (6) Nothing contained in sub-sections (1) [, (1-A)] and (2) shall apply to the following classes of assessments, reassessments and recomputation which may, subject to the provisions of [sub-sections (3), (5) and (5-A)], be completed— (i) where the assessment, reassessment or recomputation is made Digitally Signed By:KAMLESH KUMAR Signing

THE PR. COMMISSIONER OF INCOME TAX -6 vs. MARUTI SUZUKI INDIA LTD.

Bench: HON'BLE MR. JUSTICE VIPIN SANGHI,HON'BLE MR. JUSTICE SANJEEV NARULA

Transfer Pricing Officer is received by him.] (6) Nothing contained in sub-sections (1) [, (1-A)] and (2) shall apply to the following classes of assessments, reassessments and recomputation which may, subject to the provisions of [sub-sections (3), (5) and (5-A)], be completed— (i) where the assessment, reassessment or recomputation is made Digitally Signed By:KAMLESH KUMAR Signing

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

10 AA of the income tax act. Accordingly, ground number 4 of the appeal is allowed. 40. The ground number 5 is with respect to the claim of the assessee to allow/enhance the deduction by disallowance u/s 40 (a) of the act of ₹ 200,373,067. As we have already deleted the above disallowance as per ground, number