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

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 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

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

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 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

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

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

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

DCM SHRIRAM LIMITED,DELHI vs. ASSESSMENT UNIT, DELHI

115\nJB, we followed the judgement of Special Bench in the case of Virit\nInvestment (supra) where it is held that no addition could be made\non account of disallowance under section 14A to the book profit.\nThis being so, we do not find any force in the arguments of Ld. CIT\nDR accordingly, the additional grounds of appeal taken

DCM SHRIRAM LTD,NEW DELHI vs. ACIT, CIRCLE-7(1), NEW DELHI

115\nJB, we followed the judgement of Special Bench in the case of Virit\nInvestment (supra) where it is held that no addition could be made\non account of disallowance under section 14A to the book profit.\nThis being so, we do not find any force in the arguments of Ld. CIT\nDR accordingly, the additional grounds of appeal taken

DCIT, NEW DELHI vs. DCM SHRIRAM LTD, NEW DELHI

115\nJB, we followed the judgement of Special Bench in the case of Virit\nInvestment (supra) where it is held that no addition could be made\non account of disallowance under section 14A to the book profit.\nThis being so, we do not find any force in the arguments of Ld. CIT\nDR accordingly, the additional grounds of appeal taken

DCM SHRIIRAM LIMITED,NEW DELHI vs. NEAC, NEW DELHI

115\nJB, we followed the judgement of Special Bench in the case of Virit\nInvestment (supra) where it is held that no addition could be made\non account of disallowance under section 14A to the book profit.\nThis being so, we do not find any force in the arguments of Ld. CIT\nDR accordingly, the additional grounds of appeal taken

PEPSICO INDIA HOLDINGS PVT. LTD.,GURGAON vs. ACIT, CC-07, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri G. S. Pannua N D Shri Challa Nagendra Prasad

115/- is added to the TNM Method computation of Rs.150/-, it would result in the total income of Rs.265/- or a net profit of 26.5%. Even if the Assessing Officer does not reduce the AMP expenses from Rs.150/- to Rs.50/-, while computing the arm's length price by applying the TNM Method, it would vet result in unacceptable anomaly

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)

115. Learned authorized representative submitted that auditors as well as assessing officer and learned CIT - A failed to consider that due to wide variation in price of goods being transferred by division during year average method used by assessing officer to compute transfer value is not justified. It was stated that silver for division of assessee at Noida procured silver

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

sections": [ "143(3)", "144C(13)", "92CA", "92(1)", "115JB", "37(1)", "115-O" ], "issues": "The core issues involved the validity of transfer pricing

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

sections": [ "143(3)", "144C(13)", "10", "115-O", "92CA", "92(1)", "10B(1)(e)(iii)", "271(1)(c)", "37(1)", "115JB" ], "issues": "Whether the Transfer Pricing

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

sections": [ "143(3)", "144C(13)", "92CA", "10B(1)(e)(iii)", "115JB", "37(1)", "115-O", "271(1)(c)" ], "issues": "Key issues included the validity of transfer pricing