MCKINSEY KNOWLEDGE CENTRE INDIA PVT. LTD.,GURGAON vs. DCIT, NEW DELHI

In the result ground No. 14 of the appeal of the assessee is dismissed

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishimckinsey Knowledge Centre India Pvt. Vs. Dcit, Ltd, Circle-16(2) 3Rd Floor, Block-Iii, Vatika Business Park, New Delhi Sector-49, Sohna Road, Gurgaon Pan:Aaccm2356G (Appellant) (Respondent)

section 10 A of income tax act was decided. He submitted that Hon‟ble Delhi High Court in 361 ITR 85 (Delhi) in Li & Fung India private limited versus CIT has held that even in case of TNMM strict criteria is of independent enterprise, carrying out a comparable transaction, with caveat that this will only be a guide. Indeed, emphasis

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

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

transfer pricing adjustment, depreciation disallowance on computer peripherals, depreciation on cars and depreciation on buildings, the learned Dispute Resolution Panel directed the learned assessing officer to not to make such adjustment as it is not warranted according to the provisions of section 115

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

transfer pricing adjustment, depreciation disallowance on computer peripherals, depreciation on cars and depreciation on buildings, the learned Dispute Resolution Panel directed the learned assessing officer to not to make such adjustment as it is not warranted according to the provisions of section 115

M/S. AGILENT TECHNOLOGIES (INTERNATIONAL) PVT. LTD.,GURGAON vs. ACIT, GURGAON

In the result ground No. 3 of the appeal of the assessee is allowed

Bench: Smt Diva Singh & Shri Prashant Maharishiagilent Technologies Acit, (International) Pvt. Ltd, Circle-1, Vs. Plot No.-Cp-11, Sector-8, Gurgaon Imt Mangsar, Gurgaon Pan: Aadca4115C (Appellant) (Respondent)

section 115 JB of the Income Tax Act by increasing the transfer pricing adjustment made by the learned transfer-pricing

BT E- SERV (INDIA) PVT. LTD.,NEW DELHI vs. ITO, NEW DELHI

In the result appeal No. 99/Del/2016 filed by the assessee for assessment year 2011 – 12 is partly allowed

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi & Bt E-Serv (India) Pvt. Ltd, Ito, 11Th Floor, Eros Corporate Tower, Ward-5(2), Vs. Nehru Place, New Delhi New Delhi Pan:Aadcb2533M (Appellant) (Respondent)

Transfer Pricing (TP1) documentation; and pg. 3 BT e- serve ( India ) private Limited V ITO ITA No 565 /Del/2015 A Y 2010-11 ITA No 99/del/2016 A Y 2011-12 b. Determining the arm's length margins / prices using data pertaining only to financial Year ('FY') 2009-10 which was not available to the Appellant at the time of complying

JAS FORWARDING WORLDWIDE PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result appeal of the assessee for assessment year 2011 – 12 is allowed for statistical purposes

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

Section 144C of the income tax act 1961 on 28th of February 2014 determining the total income of the assessee at ₹ 332,007,300 against the returned income of ₹ 4,10,27,920/– wherein the following three additions were made i. addition on account of transfer pricing adjustment Rs 4 41,43,790/– ii. disallowance

JAS FORWARDING WORLDWIDE PVT. LTD.,GURGAON vs. DCIT, NEW DELHI

In the result appeal of the assessee for assessment year 2011 – 12 is allowed for statistical purposes

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

Section 144C of the income tax act 1961 on 28th of February 2014 determining the total income of the assessee at ₹ 332,007,300 against the returned income of ₹ 4,10,27,920/– wherein the following three additions were made i. addition on account of transfer pricing adjustment Rs 4 41,43,790/– ii. disallowance

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

price of the international transaction of IT services was determined by selecting 14 comparable companies whose average profit level indicator was 16.89%. Against this assessee is in appeal before us. 63. The first contention of the assessee is that there is an incorrect computation of operating profit margin of the assessee as foreign exchange income amounting

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

price of the international transaction of IT services was determined by selecting 14 comparable companies whose average profit level indicator was 16.89%. Against this assessee is in appeal before us. 63. The first contention of the assessee is that there is an incorrect computation of operating profit margin of the assessee as foreign exchange income amounting

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

price of the international transaction of IT services was determined by selecting 14 comparable companies whose average profit level indicator was 16.89%. Against this assessee is in appeal before us. 63. The first contention of the assessee is that there is an incorrect computation of operating profit margin of the assessee as foreign exchange income amounting

COMMISSIONER OF INCOME TAX-I vs. COTTON NATURALS (I) PVT LTD

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

section 92C, the arm's length price in relation to an international transaction 55a[or a specified domestic transaction] shall be determined by any of the following methods, being the most appropriate method, in the following manner, namely :— (a) comparable uncontrolled price method, by which,— (i) the price charged or paid for property transferred or services provided in a comparable

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)

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

ETT LTD (FORMERLY KNOWN AS INDIAN EXPRESS MULTIMEDIA LTD),NEW DELHI vs. CIT, CENTRAL-II, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Sh. Amit Shukla & Sh. Anadee Nath Misshraassessment Year: 2013-14

section 80 IA (4) (iii). Since assessee company had fulfilled all the terms and conditions as laid down in the approval granted by the Government of India for setting up of an Industrial park, therefore, it started claiming deduction 80 IA from the assessment years 2008-09 onwards and no such deduction was claim in the assessment years

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 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, 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