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

Section 92C(3) of the Act, read with the Rules. It would, among other aspects, refer to the method adopted and whether reliability and authenticity of the arm's length determination is affected or corrupted. XXXXX 91. 91. In case the tested party is engaged in single line of business, there is no bar or prohibition from applying

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

Section 92C(3) of the Act, read with the Rules. It would, among other aspects, refer to the method adopted and whether reliability and authenticity of the arm's length determination is affected or corrupted. XXXXX 91. 91. In case the tested party is engaged in single line of business, there is no bar or prohibition from applying

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

Section 92C(3) of the Act, read with the Rules. It would, among other aspects, refer to the method adopted and whether reliability and authenticity of the arm's length determination is affected or corrupted. XXXXX 91. 91. In case the tested party is engaged in single line of business, there is no bar or prohibition from applying

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

Section 92C(3) of the Act, read with the Rules. It would, among other aspects, refer to the method adopted and whether reliability and authenticity of the arm's length determination is affected or corrupted. XXXXX 91. 91. In case the tested party is engaged in single line of business, there is no bar or prohibition from applying

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

Section 92C(3) of the Act, read with the Rules. It would, among other aspects, refer to the method adopted and whether reliability and authenticity of the arm's length determination is affected or corrupted. XXXXX 91. 91. In case the tested party is engaged in single line of business, there is no bar or prohibition from applying

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

Section 92C(3) of the Act, read with the Rules. It would, among other aspects, refer to the method adopted and whether reliability and authenticity of the arm's length determination is affected or corrupted. XXXXX 91. 91. In case the tested party is engaged in single line of business, there is no bar or prohibition from applying

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

Section 92C(3) of the Act, read with the Rules. It would, among other aspects, refer to the method adopted and whether reliability and authenticity of the arm's length determination is affected or corrupted. XXXXX 91. 91. In case the tested party is engaged in single line of business, there is no bar or prohibition from applying

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

Section 92C(3) of the Act, read with the Rules. It would, among other aspects, refer to the method adopted and whether reliability and authenticity of the arm's length determination is affected or corrupted. XXXXX 91. 91. In case the tested party is engaged in single line of business, there is no bar or prohibition from applying

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

Section 92C(3) of the Act, read with the Rules. It would, among other aspects, refer to the method adopted and whether reliability and authenticity of the arm's length determination is affected or corrupted. XXXXX 91. 91. In case the tested party is engaged in single line of business, there is no bar or prohibition from applying

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)

price of goods transferred inter-unit. Accordingly, learned assessing officer is directed to consider transaction value of goods, which are not processed and sent to eligible unit, is recorded in books of accounts. With respect to goods, which are processed through job work and transferred to eligible unit, learned AO is directed to impute 2% profit over job work charges

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

Pricing Review for the FY ended 31.03.2007 (pages 643-648, 653-654 of Paper Book). He further submitted that TNMM applied by the TPO which has been accepted by the assessee takes care of minor differences in functional profile etc. and hence this company be retained as a comparable company. 14.5 We have heard the Ld. Representatives of both

MARUBENI INDIA PVT. LTD

In the result the appeal of the revenue in ITA No

transfer pricing report which it was required to submit by section 92E of the Act, the assessee chose five comparable companies and the average margin came to 8.37%. The TPO computed the arm‟s length remuneration in the following manner: - “Computation of Remuneration at Arm’s Length 2013:DHC:2072-DB ITA 1042/2011 & 1114/2011 Page 5 of 22 Personal

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

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

prices at which power was purchased from respective State Electricity Board. 64. In a case where the assessee operates a Wind Power Mill (WPP) unit at Tamil Nadu to generate electricity primarily for consumption by its manufacturing units. During the year, the assessee had transferred the WPP units at effective rate of Rs. 6.35 p.u, based on fact that Tamil

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

prices at which power was purchased from respective State Electricity Board. 64. In a case where the assessee operates a Wind Power Mill (WPP) unit at Tamil Nadu to generate electricity primarily for consumption by its manufacturing units. During the year, the assessee had transferred the WPP units at effective rate of Rs. 6.35 p.u, based on fact that Tamil

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

prices at which power was purchased from respective State Electricity Board. 64. In a case where the assessee operates a Wind Power Mill (WPP) unit at Tamil Nadu to generate electricity primarily for consumption by its manufacturing units. During the year, the assessee had transferred the WPP units at effective rate of Rs. 6.35 p.u, based on fact that Tamil

SONY INDIA PRIVATE LIMITED,NEW DELHI vs. ACIT, CIRCLE-22(2), DELHI

The appeals are allowed partly with consequence to\nfollow as per the determination of grounds as above

transfer pricing adjustment in respect of outstanding\nreceivables. In regard to this issue, it was submitted that in AY 2017-18, the\nTPO while computing the interest income for delayed receivables, has not\nrestricted the computation to assessment year under consideration. The TPO has\ncomputed the adjustment by considering interest up to the TPO's order, i.e., 31st\nJanuary

SONY INDIA PRIVATE LIMITED,NEW DELHI vs. ACIT, CIRCLE-22(2), DELHI

The appeals are allowed partly with consequence to\nfollow as per the determination of grounds as above

transfer pricing adjustment in respect of outstanding\nreceivables. In regard to this issue, it was submitted that in AY 2017-18, the\nTPO while computing the interest income for delayed receivables, has not\nrestricted the computation to assessment year under consideration. The TPO has\ncomputed the adjustment by considering interest up to the TPO's order, i.e., 31st\nJanuary

SONY INDIA PVT. LTD.,NEW DELHI vs. ACIT CIRCLE-24(1), NEW DELHI

The appeals are allowed partly with consequence to\nfollow as per the determination of grounds as above

transfer pricing adjustment in respect of outstanding\nreceivables. In regard to this issue, it was submitted that in AY 2017-18, the\nTPO while computing the interest income for delayed receivables, has not\nrestricted the computation to assessment year under consideration. The TPO has\ncomputed the adjustment by considering interest up to the TPO's order, i.e., 31st\nJanuary