DCIT, NEW DELHI vs. M/S. L.T. FOODS LTD., NEW DELHI

In the result, the appeal of the Revenue is dismissed and the appeal of the Assessee is allowed in part and for statistical purposes

Bench: Shri G.S. Pannu, Hon’Ble & Shri K.Narasimha Charydcit Vs. L.T. Foods Ltd., Central Circle-19, Unit No. 134, First Floor, 3Rd Floor, Ara Centre, Rectangle-I, Saket District Centre Jhandewalan Extn. New Delhi. New Delhi.

11A) of the Act cannot be allowed in view of explanation (2) to section 80IB of the Act which stipulates that were in the case of an industrial undertaking, any machinery or plant or any part thereof previously used for any purpose is transferred to a new business and the total value of the machinery or plant or part

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

LT FOODS LTD.,NEW DELHI vs. DCIT, NEW DELHI

The appeal of the assessee is partly allowed

Bench: Shri N.K. Billaiya & Shri Yogesh Kumar U.S

transferred to Bahalgarh unit subsequently. Such unfounded observations of the learned Assessing Officer cannot be one of the bases to deny the deduction under section 80IB(11A) of the Act. XXX XXX 63. We, accordingly find that the assessee cannot be denied the 49 deduction under section 80IB(11A) of the Act either in respect of the activities conducted

JCIT, NEW DELHI vs. M/S. DAAWAT FOODS LTD., NEW DELHI

In the result, the appeal of the assessee is partly allowed as indicated above and the appeal of the Revenue is dismissed

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

transfer pricing adjustment made on account of receivables from AE. This ground is allowed. 27.1 Coming to Revenue’s appeal the only issue for adjudication is whether ld. CIT (Appeals) erred in law and on facts of the case in allowing the assessee deduction under section 80IB(11A

DAWAT FOODS LTD.,GURGAON vs. ACIT, NEW DELHI

In the result, the appeal of the assessee is partly allowed as indicated above and the appeal of the Revenue is dismissed

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

transfer pricing adjustment made on account of receivables from AE. This ground is allowed. 27.1 Coming to Revenue’s appeal the only issue for adjudication is whether ld. CIT (Appeals) erred in law and on facts of the case in allowing the assessee deduction under section 80IB(11A

M/S. ARIBA INC.,GURGAON vs. ADIT, NEW DELHI

In the result, all these appeals filed by the assessee stand partly

Price Waterhouse Coopers, International Taxation, Sucheta Bhawan, 11A, Circle 1 (1), Vishnu Digamber Marg, New Delhi. New Delhi. (PAN : AAACD5883D) (APPELLANT) (RESPONDENT) ASSESSEE BY : Shri Himanshu Sinha, Advocate Shri Yash Varmani, Advocate REVENUE BY : Shri Sanjay Kumar, Sr. DR 2 ITA Nos.4582 to 4584, 6090/Del./2010 ITA No.3923/Del./2012 ITA No.1538/Del./2013 ITA Nos.1469 & 1470/Del./2015 Date of Hearing

ARIBA INC,NEW DELHI vs. ADIT (INTL TAXATION), NEW DELHI

In the result, all these appeals filed by the assessee stand partly

Price Waterhouse Coopers, International Taxation, Sucheta Bhawan, 11A, Circle 1 (1), Vishnu Digamber Marg, New Delhi. New Delhi. (PAN : AAACD5883D) (APPELLANT) (RESPONDENT) ASSESSEE BY : Shri Himanshu Sinha, Advocate Shri Yash Varmani, Advocate REVENUE BY : Shri Sanjay Kumar, Sr. DR 2 ITA Nos.4582 to 4584, 6090/Del./2010 ITA No.3923/Del./2012 ITA No.1538/Del./2013 ITA Nos.1469 & 1470/Del./2015 Date of Hearing

ARIBA INC,NEW DELHI vs. ADIT (INTL TAXATION), NEW DELHI

In the result, all these appeals filed by the assessee stand partly

Price Waterhouse Coopers, International Taxation, Sucheta Bhawan, 11A, Circle 1 (1), Vishnu Digamber Marg, New Delhi. New Delhi. (PAN : AAACD5883D) (APPELLANT) (RESPONDENT) ASSESSEE BY : Shri Himanshu Sinha, Advocate Shri Yash Varmani, Advocate REVENUE BY : Shri Sanjay Kumar, Sr. DR 2 ITA Nos.4582 to 4584, 6090/Del./2010 ITA No.3923/Del./2012 ITA No.1538/Del./2013 ITA Nos.1469 & 1470/Del./2015 Date of Hearing

ARIBA INC.,NEW DELHI vs. ADIT, NEW DELHI

In the result, all these appeals filed by the assessee stand partly

Price Waterhouse Coopers, International Taxation, Sucheta Bhawan, 11A, Circle 1 (1), Vishnu Digamber Marg, New Delhi. New Delhi. (PAN : AAACD5883D) (APPELLANT) (RESPONDENT) ASSESSEE BY : Shri Himanshu Sinha, Advocate Shri Yash Varmani, Advocate REVENUE BY : Shri Sanjay Kumar, Sr. DR 2 ITA Nos.4582 to 4584, 6090/Del./2010 ITA No.3923/Del./2012 ITA No.1538/Del./2013 ITA Nos.1469 & 1470/Del./2015 Date of Hearing

ARIBA INC.,NEW DELHI vs. ADIT, NEW DELHI

In the result, all these appeals filed by the assessee stand partly

Price Waterhouse Coopers, International Taxation, Sucheta Bhawan, 11A, Circle 1 (1), Vishnu Digamber Marg, New Delhi. New Delhi. (PAN : AAACD5883D) (APPELLANT) (RESPONDENT) ASSESSEE BY : Shri Himanshu Sinha, Advocate Shri Yash Varmani, Advocate REVENUE BY : Shri Sanjay Kumar, Sr. DR 2 ITA Nos.4582 to 4584, 6090/Del./2010 ITA No.3923/Del./2012 ITA No.1538/Del./2013 ITA Nos.1469 & 1470/Del./2015 Date of Hearing

M/S. ARIBA INC.,GURGAON vs. ADIT, NEW DELHI

In the result, all these appeals filed by the assessee stand partly

Price Waterhouse Coopers, International Taxation, Sucheta Bhawan, 11A, Circle 1 (1), Vishnu Digamber Marg, New Delhi. New Delhi. (PAN : AAACD5883D) (APPELLANT) (RESPONDENT) ASSESSEE BY : Shri Himanshu Sinha, Advocate Shri Yash Varmani, Advocate REVENUE BY : Shri Sanjay Kumar, Sr. DR 2 ITA Nos.4582 to 4584, 6090/Del./2010 ITA No.3923/Del./2012 ITA No.1538/Del./2013 ITA Nos.1469 & 1470/Del./2015 Date of Hearing

ARIBA INC.,NEW DELHI vs. ADIT, NEW DELHI

In the result, all these appeals filed by the assessee stand partly

Price Waterhouse Coopers, International Taxation, Sucheta Bhawan, 11A, Circle 1 (1), Vishnu Digamber Marg, New Delhi. New Delhi. (PAN : AAACD5883D) (APPELLANT) (RESPONDENT) ASSESSEE BY : Shri Himanshu Sinha, Advocate Shri Yash Varmani, Advocate REVENUE BY : Shri Sanjay Kumar, Sr. DR 2 ITA Nos.4582 to 4584, 6090/Del./2010 ITA No.3923/Del./2012 ITA No.1538/Del./2013 ITA Nos.1469 & 1470/Del./2015 Date of Hearing

ARIBA INC,NEW DELHI vs. ADIT (INTL TAXATION), NEW DELHI

In the result, all these appeals filed by the assessee stand partly

Price Waterhouse Coopers, International Taxation, Sucheta Bhawan, 11A, Circle 1 (1), Vishnu Digamber Marg, New Delhi. New Delhi. (PAN : AAACD5883D) (APPELLANT) (RESPONDENT) ASSESSEE BY : Shri Himanshu Sinha, Advocate Shri Yash Varmani, Advocate REVENUE BY : Shri Sanjay Kumar, Sr. DR 2 ITA Nos.4582 to 4584, 6090/Del./2010 ITA No.3923/Del./2012 ITA No.1538/Del./2013 ITA Nos.1469 & 1470/Del./2015 Date of Hearing

COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION- 2, NEW DELHI vs. HYUNDAI ROTEM COMPANY

The appeal is dismissed

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

Transfer Pricing Officer passed under sub-section (3) of Section 92-CA; and (ii) any non-resident not being a company, or any foreign company.‖ 17. As is manifest from a reading of sub-section (13) of Section 144C of the Act, the AO is not accorded any discretion in the framing of an order of assessment once directions have

DCIT, CIRCLE- 1(2)(1), INTERNATIONAL TAXATION , NEW DELHI vs. CONVERGYS CUSTOMER MANAGEMENT GROUP INC., NEW DELHI

In the result, assessee’s appeal is partly allowed, whereas,

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Deyassessment Year: 2014-15

11A, Vishnu Digambar Marg, New Delhi PAN :AACCC8989M (Appellant) (Respondent) WITH Assessment Year: 2014-15 M/s. Convergys Customer Vs. DCIT, Management Group Inc., Circle-1(2)(1), Intl. Taxation, C/o-PricewaterhouseCoopers New Delhi (P) Ltd., Sucheta Bhavan, Gate No.2, 1st Floor, 11-A, Vishnu Digambar Marg, New Delhi PAN :AACCC8989M (Appellant) (Respondent) Assessee by Sh. Ravi Sharma, Advocate Sh. Rishabh Malhotra

EBRO INDIA PVT.LTD. ,DELHI vs. ACIT CIRCLE-7(1), DELHI

In the result, the ground no 4 raised by the assessee is allowed

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Accountant Member)

Transfer Pricing Officer (TPO) under section 92CA of the Act. During such proceedings, - the TPO, vide notice dated 25.02.2021, inter-alia, required the assessee to submit the details of change in shareholding structure and other international transactions [refer pages 97-98 of paperbook]; and - in response thereto, the appellantvide reply dated 07.07.2021 submitted (as Annexure-11 to the reply

ADIDAS INDIA MARKETING PVT. LTD.,NEW DELHI vs. NATIONAL E- ASSESSMENT CENTRE, NEW DELHI

In the result, appeal of the assessee is allowed

Bench: Sh. Anil Chaturvedi & Sh. Yogesh Kumar Us & Stay Application No.73/Del/2021 (Assessment Year : 2016-17)

Price Waterhouse & New Delhi Co. LLP Sucheta Bhawan, Gate No. FF, 11A, Vishnu DIGAMBAR MARG, New Delhi, Delhi – 110002. PAN : AAACA 5313 P (APPELLANT) (RESPONDENT) Assessee by Shri Rishabh Malhotra, A.R. Shri Ravi Sharma, Adv. Revenue by Shri Surender Pal, CIT (D.R.) Shri Mrinal Kumar Das, Sr. D.R. Date of hearing: 24.03.2022 Date of Pronouncement: 05.04.2022 ORDER PER ANIL CHATURVEDI

ARISTOCRAT TECHNOLOGIES INDIA PRIVATE LIMITED,NOIDA vs. DCIT, CIRCLE-5(1)(1), NOIDA

In the result, appeal of the assessee is partly allowed in the terms aforesaid

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.3091/िद"ी/2024(िन.व. 2020-21) Aristocrat Technologies India P. Ltd., 8Tgh To 10Th Floor, Tower-11A, Plot No. 20 & 21, Candor Techspace, It/Ites Sez Complex, Sector-135, Noida, Up 201304 ...... अपीलाथ"/Appellant Pan: Aahca-9200-G बनाम Vs. Deputy Commissioner Of Income Tax, ..... "ितवादी/Respondent Circle-5(1)(1), Noida, Up Assessee By : Shri Atul Jain, Chartered Accountant Ms. Nishi Bhutani & Ms.Preeti Agnihotri, Chartered Accountants Department By : S/Shri S.K. Jhadav, Cit(Dr) & Rajesh Kumar Dhaneshta, Sr.Dr सुनवाई क" ितिथ/ Date Of Hearing : 04/04/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 03/07/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Assessment Order Dated 27.05.2024 Passed U/S. 143(3) R.W.S. 144C(13) R.W.S 144B Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’). 2. The Facts Of The Case In Brief As Emanating From Records Are: The Assessee Is Engaged In Providing Design & Development Services To Its Associated Enterprises (Ae’S). The Assessee Is Also Rendering Global It Services To Its Ae’S

11A, Plot No. 20 & 21, Candor Techspace, IT/ITes SEZ Complex, Sector-135, Noida, UP 201304 ...... अपीलाथ"/Appellant PAN: AAHCA-9200-G बनाम Vs. Deputy Commissioner of Income Tax, ..... "ितवादी/Respondent Circle-5(1)(1), Noida, UP Assessee by : Shri Atul Jain, Chartered Accountant Ms. Nishi Bhutani & Ms.Preeti Agnihotri, Chartered Accountants Department by : S/Shri S.K. Jhadav, CIT(DR) & Rajesh Kumar Dhaneshta