COMMISSIONER OF INCOME TAX vs. AMADEUS INDIA PVT LTD

Appeal is dismissed

11A plainly indicates its prospective operation. …” 20. Similarly, in the case before us, we find that there is nothing in the statute to indicate that sub-section (2A) was introduced in a manner so as to operate with retrospective effect. Sub-section (2A) expands the jurisdiction of the Transfer Pricing Officer by empowering him to determine the arm’s length

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

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

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, 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

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) of the Act. The assessee had, in the previous year relevant

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) of the Act. The assessee had, in the previous year relevant

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

ASSISSTANT COMMISSIONER OF INCOME TAX, JHANDEWALAN EXTN. vs. OM PRAKASH ARORA, CONNAUGHT PLACE

In the result, appeal of the Revenue vide ITA No

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2015-16] Assistant Commissioner Of Om Prakash Arora, Income Tax, Central Circle-01, M-3, Flat No.103, Avg Bhawan E-2, Jhandewalan Extn. Vs The Variety Books Depot. New Delhi-110055 Connaught Place, New Delhi-110001 Pan-Accpa9774F Assessee Revenue Cross Objection No.42/Del/2025 (Arising Out Of Ita No.5031/Del/2024) [Assessment Year: 2015-16] Om Prakash Arora, Assistant Commissioner Of Income M-3, Flat No.103, Avg Tax, Central Circle-01, Bhawan The Variety Books Vs E-2, Jhandewalan Extn. Depot. Connaught Place, New Delhi-110055 New Delhi-110001 Pan-Accpa9774F Assessee Revenue [Assessment Year: 2016-17] Assistant Commissioner Of Om Prakash Arora, Income Tax, Central Circle-01, M-3, Flat No.103, Avg Bhawan E-2, Jhandewalan Extn. Vs The Variety Books Depot. New Delhi-110055 Connaught Place, New Delhi-110001 Pan-Accpa9774F Assessee Revenue

1). We are therefore of the considered view that no case of any intervention Page 20 of 54 ITA Nos.5029 & 5031/Del/2024 & CO No.42/Del/2025 to the order of the ld. CIT(A) is made out at this stage. We therefore confirm the order of the ld. CIT(A) and dismiss the ground of appeal no.2 raised by the Revenue

ASSISSTANT COMMISSIONER OF INCOME TAX, JHANDEWALAN EXTN. vs. OM PRAKASH ARORA, CONNAUGHT PLACE

In the result, appeal of the Revenue vide ITA No

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2015-16] Assistant Commissioner Of Om Prakash Arora, Income Tax, Central Circle-01, M-3, Flat No.103, Avg Bhawan E-2, Jhandewalan Extn. Vs The Variety Books Depot. New Delhi-110055 Connaught Place, New Delhi-110001 Pan-Accpa9774F Assessee Revenue Cross Objection No.42/Del/2025 (Arising Out Of Ita No.5031/Del/2024) [Assessment Year: 2015-16] Om Prakash Arora, Assistant Commissioner Of Income M-3, Flat No.103, Avg Tax, Central Circle-01, Bhawan The Variety Books Vs E-2, Jhandewalan Extn. Depot. Connaught Place, New Delhi-110055 New Delhi-110001 Pan-Accpa9774F Assessee Revenue [Assessment Year: 2016-17] Assistant Commissioner Of Om Prakash Arora, Income Tax, Central Circle-01, M-3, Flat No.103, Avg Bhawan E-2, Jhandewalan Extn. Vs The Variety Books Depot. New Delhi-110055 Connaught Place, New Delhi-110001 Pan-Accpa9774F Assessee Revenue

1). We are therefore of the considered view that no case of any intervention Page 20 of 54 ITA Nos.5029 & 5031/Del/2024 & CO No.42/Del/2025 to the order of the ld. CIT(A) is made out at this stage. We therefore confirm the order of the ld. CIT(A) and dismiss the ground of appeal no.2 raised by the Revenue

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

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

JCIT SPL. RANGE-12, NEW DELHI vs. ARIHANTA INDUSTRIES, DELHI

In the result, both the appeals of the Revenue are allowed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

price. However, on perusal of the balance sheet of M/s Krishna Enterprises it has been seen that on the sale of goods Rs. 2,05,86,268/- the party has earned gross profit of Rs. 3,03,088/- only which is including the expenses of freight, employees salary and other expenses for sale of these products, more

DCIT, CC-15, NEW DELHI vs. BDR BUILDERS & DEVELOPERS P. LTD., NEW DELHI

In the result, the appeal of the Revenue is dismissed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Usasstt. Year: 2012-13 Dcit, Vs. Bdr Builders & Developers P. Ltd,B- Central Circle-15, 393, Zakir Nagar So, South East Delhi, New Delhi New Delhi-1100025 (Appellant) (Respondent) Pan No. Assessee By : Dr. Rakesh Gupta, Adv. Revenue By : Sh. Kanv Bali, Sr. Dr Date Of Hearing: 28.02.2023 Date Of Pronouncement: 16.03.2023

11A. Heard, the arguments of both the parties and perused the material available on record. We have perused the order of the ld CIT(A) in detail. For the sake of ready reference the said order adjudicating the issue is reproduced as under:- “6. Ground Nos. 1 to 5: I have considered the facts of the case and written submissions