BENTLEY SYSTEMS INDIA PVT. LTD.,NEW DELHI vs. DCIT, CIRCLE- 4(2), NEW DELHI

In the result, the appeal of assessee is partly allowed

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kediaassessment Year: 2014-15

transfer pricing adjustment, as provided under Chapter X, is specifically included under section 115JB, no such adjustment can be made. 30. In the case of Apollo Tyres Vs. CIT (supra), the Hon’ble Supreme Court while referring to pari materia provisions contained under Section 115J

INNOVATIVE TEXTILES LIMITED,DELHI vs. DCIT, CIRCLE-10(1), NEW DELHI

In the result, the appeal of the assessee is partly allowed

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Innovative Textiles Limited, Vs. Dcit, Circle 10(1), 81, Vighyan Vihar, New Delhi. Delhi – 110 092. (Pan : Aaaci0473J) (Appellant) (Respondent) Assessee By : Shri Gautam Jain, Advocate Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 05.08.2025 Date Of Order : 24.09.2025 O R D E R Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against Assessment Order Dated 26.03.2022 Passed By The Income Tax Department/National Faceless Assessment Centre, Delhi U/S 143(3) Read With Section 144C(13)/144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2017-18 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act Raising Following Grounds Of Appeal :- “1. That The Orders Of The Learned Lower Tax Authorities Is/Are Contrary To The Law & Facts Of The Case.

section 115J.” 5. We observe that the coordinate Bench in the case of Cash Edge India Pvt. Ltd. (supra) had considered the exactly similar issue. For the sake of brevity, it is reproduced below :- “34. In this regard, the learned counsel for the assessee submitted that the AO has added the transfer pricing

DCIT (LTU), NEW DELHI vs. M/S. EXL SERVICE.COM (INDIA) PVT. LTD., NEW DELHI

In the result, the appeal by the assessee as well as ofthe department are partly allowed for statistical purposes

Bench: Sh. N. K. Saini, Am & Sh. Kuldip Singh, Jm Ita No. 302/Del/2015 : Asstt. Year : 2010-11 Exl Service.Com (India) Pvt. Ltd., Vs Deputy Commissioner Of Income 414, 4Th Floor, Dlf Jasola, Tax, Large Tax Payer Unit, Tower-B, Plot No. 10 & 11, Dda New Delhi District Centre, Jasola, New Delhi-110044 (Appellant) (Respondent) Ita No. 615/Del/2015 : Asstt. Year : 2010-11 Deputy Commissioner Of Income Vs Exl Service.Com (India) Pvt. Ltd., 414, 4Th Floor, Dlf Jasola, Tower- Tax, Circle-1 (Ltu), New Delhi-110017 B, Plot No. 10 & 11, Dda District Centre, Jasola, New Delhi-110044 (Appellant) (Respondent) Pan No. Aaace5174C Assessee By : Sh. Ajay Vohra, Adv. Sh. Abhishek Agarwal, Adv. Revenue By : Sh. Piyush Jain, Cit Dr Date Of Hearing : 07.10.2017 Date Of Pronouncement : 03.01.2017 Order Per N. K. Saini, Am:

Transfer Pricing regulation would be applicable to any transaction being arrangement, understanding or action in concert, inter alia, in the nature of purchase, sale or lease of tangible or intangible property or any other transaction having bearing on profits, income, losses or assets of such enterprises. Therefore, the continuing debit balance only reflects that the payment, even though

EXL SERVICE.COM (INDIA) PVT. LTD.,NEW DELHI vs. DCIT (LTU), NEW DELHI

In the result, the appeal by the assessee as well as ofthe department are partly allowed for statistical purposes

Bench: Sh. N. K. Saini, Am & Sh. Kuldip Singh, Jm Ita No. 302/Del/2015 : Asstt. Year : 2010-11 Exl Service.Com (India) Pvt. Ltd., Vs Deputy Commissioner Of Income 414, 4Th Floor, Dlf Jasola, Tax, Large Tax Payer Unit, Tower-B, Plot No. 10 & 11, Dda New Delhi District Centre, Jasola, New Delhi-110044 (Appellant) (Respondent) Ita No. 615/Del/2015 : Asstt. Year : 2010-11 Deputy Commissioner Of Income Vs Exl Service.Com (India) Pvt. Ltd., 414, 4Th Floor, Dlf Jasola, Tower- Tax, Circle-1 (Ltu), New Delhi-110017 B, Plot No. 10 & 11, Dda District Centre, Jasola, New Delhi-110044 (Appellant) (Respondent) Pan No. Aaace5174C Assessee By : Sh. Ajay Vohra, Adv. Sh. Abhishek Agarwal, Adv. Revenue By : Sh. Piyush Jain, Cit Dr Date Of Hearing : 07.10.2017 Date Of Pronouncement : 03.01.2017 Order Per N. K. Saini, Am:

Transfer Pricing regulation would be applicable to any transaction being arrangement, understanding or action in concert, inter alia, in the nature of purchase, sale or lease of tangible or intangible property or any other transaction having bearing on profits, income, losses or assets of such enterprises. Therefore, the continuing debit balance only reflects that the payment, even though

M/S GUJARAT GUARDIAN LTD.,,NEW DELHI vs. DCIT,, NEW DELHI

Pricing regulations all the methods stand on equal footing.\n\n(d) The transaction of export of glass is closely linked with the overall operations of the assessee. It is submitted that the assessee was the first company to set up the float glass plant in India. Until that time float glass was not known in the Indian market

ACIT, GURGAON vs. M/S. COMVERSE NETWORKS SYSTEM INDIA PVT. LTD., GURGAON

In the result, the appeal of the revenue stands partly

Bench: Shri N.S. Saini & Shri Sudhanshu Srivastavaay: 2004-05

section 92C of the Act is not available to the Respondent.” 3.0 The Ld. Senior Departmental Representative (Sr. DR) submitted that the assessee had selected four comparables in the Transfer Pricing study viz. Enviro Technologies Ltd., Intelligent Communication System (India) Limited, Yashmun Engineers Limited and Vaibhav Heavy Vehicles Limited. The Ld. Sr. DR 6 C.O. No. 94/D/2016 submitted that with

GUJARAT GUARDIAN LTD.,,NEW DELHI vs. DCIT, NEW DELHI

Pricing regulations all\nthe methods stand on equal footing.\n(d) The transaction of export of glass is closely linked with the\noverall operations of the assessee. It is submitted that the assessee\nwas the first company to set up the float glass plant in India. Until\nthat time float glass was not known in the Indian market and\nconventional

GUJARAT GUARDIAN LTD.,,NEW DELHI vs. DCIT, NEW DELHI

Pricing regulations all the methods stand on equal footing.\n\n(d) The transaction of export of glass is closely linked with the overall operations of the assessee. It is submitted that the assessee was the first company to set up the float glass plant in India. Until that time float glass was not known in the Indian market

GUJARAT GUARDIAN LTD.,NEW DELHI vs. DCIT, NEW DELHI

Pricing regulations all\nthe methods stand on equal footing.\n(d) The transaction of export of glass is closely linked with the\noverall operations of the assessee. It is submitted that the assessee\nwas the first company to set up the float glass plant in India. Until\nthat time float glass was not known in the Indian market and\nconventional

DCIT, NEW DELHI vs. M/S. GUJRAT GUARDIAN LTD., NEW DELHI

Pricing regulations all\nthe methods stand on equal footing.\n(d) The transaction of export of glass is closely linked with the\noverall operations of the assessee. It is submitted that the assessee\nwas the first company to set up the float glass plant in India. Until\nthat time float glass was not known in the Indian market and\nconventional

ACIT, NEW DELHI vs. M/S GUJARAT GUARDIAN LTD., NEW DELHI

Pricing regulations all\nthe methods stand on equal footing.\n(d) The transaction of export of glass is closely linked with the\noverall operations of the assessee. It is submitted that the assessee\nwas the first company to set up the float glass plant in India. Until\nthat time float glass was not known in the Indian market and\nconventional

DCIT, NEW DELHI vs. M/S GUJRAT GUARDIAN LTD.,, NEW DELHI

Pricing regulations all\nthe methods stand on equal footing.\n\n(d) The transaction of export of glass is closely linked with the\noverall operations of the assessee. It is submitted that the assessee\nwas the first company to set up the float glass plant in India. Until\nthat time float glass was not known in the Indian market

SHREE CHANDI MAA MAHAKALI PRACHIN MANDIR SIDH PEETH SAMITI,SONIPAT vs. CPC, BANGLORE

Pricing regulations all\nthe methods stand on equal footing.\n(d) The transaction of export of glass is closely linked with the\noverall operations of the assessee. It is submitted that the assessee\nwas the first company to set up the float glass plant in India. Until\nthat time float glass was not known in the Indian market and\nconventional

GUJRAT GUARDIAN LTD.,NEW DELHI vs. DCIT, NEW DELHI

Pricing regulations all\nthe methods stand on equal footing.\n(d) The transaction of export of glass is closely linked with the\noverall operations of the assessee. It is submitted that the assessee\nwas the first company to set up the float glass plant in India. Until\nthat time float glass was not known in the Indian market and\nconventional

DCIT, CIRCLE- 17(2), NEW DELHI vs. NALWA STEEL AND POWER LTD., NEW DELHI

In the result, ITA No. 5548/Del/2017 of the Revenue is dismissed

Bench: Dr. Brr Kumar & Shri Yogesh Kumar U.S.Assessment Year: 2011-12

price of power for the purposes of computing deduction admissible to power units u/s 80-1A of the I.T. Act. We find the assessee in the instant case has sold the electricity to its captive plant 7 ITA No.5548 & 4941/Del./2017 Nalwa Steel & Power Ltd. at the rate of Rs.3.92 per unit i.e. rate at which CSEB was selling

NALWA STEEL POWER LIMITED,NEW DELHI vs. ACIT, CIRCLE- 13(3), NEW DELHI

In the result, ITA No. 5548/Del/2017 of the Revenue is dismissed

Bench: Dr. Brr Kumar & Shri Yogesh Kumar U.S.Assessment Year: 2011-12

price of power for the purposes of computing deduction admissible to power units u/s 80-1A of the I.T. Act. We find the assessee in the instant case has sold the electricity to its captive plant 7 ITA No.5548 & 4941/Del./2017 Nalwa Steel & Power Ltd. at the rate of Rs.3.92 per unit i.e. rate at which CSEB was selling

HINDUSTAN COCA COLA BEVERAGES PVT. LTD vs. DCIT CIRCLE 12 (1),

In the result, the appeal filed by the assessee is partly allowed for statistical purposes and the appeal filed by the Revenue is dismissed

Bench: Shri R.K. Panda & Shri Kuldip Singhassessment Year: 2003-04

Transfer Pricing Officer after a due verification of the service charges had found the same to be satisfactory. 11 The CIT(A) erred in relying on the certain third party confirmations received by the assessing officer for processing charges without providing a copy of the said confirmations to the appellant company to explain the reasons for differences

ORIENTAL BANK OF COMMERCE,GURGAON vs. ACIT, SPL. RANGE-07, NEW DELHI

In the result, the appeal filed by the Assessee stands allowed

Bench: Shri Anil Chaturvedi & Shri N.K. Choudhryassessment Year: 2016-17

price is higher than the face value, 12 ‘the premium should be amortized for the remaining period of maturity of the security’. From the above, it is clear that the premium has to be amortized for the remaining period of maturity of the security. The learned authorized representative fairly conceded that details of such premium splitting over the remaining period

DCIT, NEW DELHI vs. M/S. ASAHI INDIA GLASS LIMITED, NEW DELHI

In the result, the appeal filed by the assessee is partly allowed for

Bench: Shri R. K. Panda & Ms. Suchitra Kambleassessment Year : 2007-08 Asahi India Glass Limited, Dcit, Circle- 2(1), 38, Okhla Industrial Area, New Delhi. Vs. Phase- Iii, New Delhi.

115J and 115JA in levying of interest u/s 234B. He accordingly submitted that the grounds raised by the assessee should be dismissed. 21. We have heard the rival contentions made by both the sides, perused the materials available on record and the Paper Book filed on behalf of the assessee. We have also considered the various decisions cited before