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 proposed by the TPO. In this regard it is noted by the Ld DRP that tax department has filed an SLP before the Hon’ble Apex 15 Stay No. 475, 476/d/2018& ITA no. 1662/d/2016 (Amadeus India P. Ltd.) Court and, thereafter, to the extent the decision of the Hon’ble Delhi High Court in case of Sony

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 proposed by the TPO. In this regard it is noted by the Ld DRP that tax department has filed an SLP before the Hon’ble Apex 15 Stay No. 475, 476/d/2018& ITA no. 1662/d/2016 (Amadeus India P. Ltd.) Court and, thereafter, to the extent the decision of the Hon’ble Delhi High Court in case of Sony

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 proposed by the TPO. In this regard it is noted by the Ld DRP that tax department has filed an SLP before the Hon’ble Apex 15 Stay No. 475, 476/d/2018& ITA no. 1662/d/2016 (Amadeus India P. Ltd.) Court and, thereafter, to the extent the decision of the Hon’ble Delhi High Court in case of Sony

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)

Section 92E Page 11 of 19 was not furnished, are matters that can be argued and adjudicated in appeal". In the instant facts, it is apparent that during the relevant period there is no impact on profitability in respect to the international transactions with AE. Thus, the reference by AO to TPO is bad in law. The Hon'ble Apex

M/S TRL RICELAND PVT. LTD.,(FORMERLY KNOWN AS M/S TILDA RICELAND P.LTD.),NEW DELHI vs. ADDLCIT, NEW DELHI

Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing)

section 92D, "shall be supported by authentic documents, which may include the following (i.e. documents specified therein)". The logic employed by the Transfer Pricing Officer is that since databases compiled by private entities is not included in rule 10 D(3), such databases cannot be relied upon by the assessee. This logic is clearly fallacious inasmuch as an item

TRL RICELAND PVT. LTD.,(FORMERLY KNOWN AS M/S TILDA RICELAND P.LTD.),NEW DELHI vs. ADDL.CIT, SPECIAL RANGE- 9, NEW DELHI

Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing)

section 92D, "shall be supported by authentic documents, which may include the following (i.e. documents specified therein)". The logic employed by the Transfer Pricing Officer is that since databases compiled by private entities is not included in rule 10 D(3), such databases cannot be relied upon by the assessee. This logic is clearly fallacious inasmuch as an item

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

113,27,64,370 under normal provisions of the Act. Transfer Pricing issue: 2. That the assessing officer/DRP erred on facts and in law in making an adjustment of Rs. 11,70,02,000 to the arm‟s length price of the „international transaction‟ of provision of IT enabled services on the basis of the order passed under section

STERIA (INDIA) LTD.,NOIDA vs. ADDL. CIT, SPL. RANGE- 8 , NEW DELHI

In the result ITA number 5745/del/2018 for assessment year 2014 – 15

Bench: Shri Kuldip Singh & Shri Prashant Maharishi

113,27,64,370 under normal provisions of the Act. Transfer Pricing issue: 2. That the assessing officer/DRP erred on facts and in law in making an adjustment of Rs. 11,70,02,000 to the arm‟s length price of the „international transaction‟ of provision of IT enabled services on the basis of the order passed under section

STERIA INDIA LTD.,NOIDA vs. ADDL.CIT, SPECIAQL RANGE-8, NEW DELHI

In the result ITA number 5745/del/2018 for assessment year 2014 – 15

Bench: Shri Kuldip Singh & Shri Prashant Maharishi

113,27,64,370 under normal provisions of the Act. Transfer Pricing issue: 2. That the assessing officer/DRP erred on facts and in law in making an adjustment of Rs. 11,70,02,000 to the arm‟s length price of the „international transaction‟ of provision of IT enabled services on the basis of the order passed under section

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 passed under sub-section (3) of section 92CA. For this class of assessees, it prescribes a collegium of three commissioners, once objections are preferred. The Dispute Resolution Panel's powers are coterminous with the Commissioner of Income-tax (Appeals), including the power to confirm, reduce or enhance the variation proposed and to consider the issues not agitated

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 passed under sub-section (3) of section 92CA. For this class of assessees, it prescribes a collegium of three commissioners, once objections are preferred. The Dispute Resolution Panel's powers are coterminous with the Commissioner of Income-tax (Appeals), including the power to confirm, reduce or enhance the variation proposed and to consider the issues not agitated

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 passed under sub-section (3) of section 92CA. For this class of assessees, it prescribes a collegium of three commissioners, once objections are preferred. The Dispute Resolution Panel's powers are coterminous with the Commissioner of Income-tax (Appeals), including the power to confirm, reduce or enhance the variation proposed and to consider the issues not agitated

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)

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

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

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

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

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

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

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

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

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

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent