ECOENERGY INSIGHTS LTD ( FORMERLY KNOWN AS CHUBB ALBA CONTROL SYSTEMS P.LTD),NEW DELHI vs. DCIT, CIRCLE-4(2), NEW DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaecoenergy Insights Ltd., Vs. Dcit, (Formerly Known As Chubb Alba Control Circle 4 (2), Systems P. Ltd.), New Delhi. Ground Floor, 18, Netaji Subhash Marg, Daryaganj, New Delhi – 110 002. (Pan :Aaaca0031C) (Appellant) (Respondent) Assessee By : Shri Nageshwar Rao, Advocate Shri Parth, Advocate Shri Pratik Rath, Advocate Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 12.08.2025 Date Of Order : 10.11.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Assessment Order Dated 25.07.2022Passed By The Assessment Unit, Income Tax Department Under Section 147 Read With Section 144C(13) R.W.S. 144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Ay 2018-19 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act.

section 1448 would show that there is no provision for Technical Unit to make reference to TPO, as Technical Unit itself is authorised to perform functions of providing technical assistance for transfer pricing. Further delegation by one TPO (Technical Unit under faceless regime) to TPO (erstwhile physical assessment regime) is not permissible on a plain reading of provisions

ACIT, CIRCLE-8(1), NEW DELHI vs. EFS FACILITIES SERVICES (INDIA) PVT. LTD., NEW DELHI

In the result, both the appeals of the Revenue for assessment year

Bench: Dr. B.R.R. Kumar & Ms. Astha Chandra

AC Units etc. 3.1 The assessee filed its return of income declaring a loss of Rs. 4,78,16,076/- on 29.11.2013. The case was selected for scrutiny through CASS. Statutory notices alongwith questionnaire were issued which were duly responded by the assessee. The assessee submitted details/documents which were placed on record of the Ld. Assessing Officer (“AO”). The books

ACIT, CIRCLE-8(1), NEW DELHI vs. EFS FACILITIES SERVICES (INDIA) PVT. LTD., NEW DELHI

In the result, both the appeals of the Revenue for assessment year

Bench: Dr. B.R.R. Kumar & Ms. Astha Chandra

AC Units etc. 3.1 The assessee filed its return of income declaring a loss of Rs. 4,78,16,076/- on 29.11.2013. The case was selected for scrutiny through CASS. Statutory notices alongwith questionnaire were issued which were duly responded by the assessee. The assessee submitted details/documents which were placed on record of the Ld. Assessing Officer (“AO”). The books

BAXTER INDIA PRIVATE LIMITED,GURGAON, HARYANA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, NEW DELHI

In the result, appeals of the Assessee are allowed

pricing order under section 92CA(3) of the Act passed.\nDraft assessment order under section 144C(1) of the Act passed.\n: Limitation for passing the final assessment order expired on\n30.09.2023 i.e. 30 months (18 months+ 12 months) from April 01, 2021\nin view of section 153(1) read with section 153(4) of the Act.\nRefer ground

CLAAS AGRICULTURAL MACHINERY PRIVATE LIMITED,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 4(2), NEW DELHI, NEW DELHI

In the result, appeal of the Assessee is allowed

Pricing order u/s 92CA(3) of the Act\npassed.\n21.09.2023\n:\nDraft assessment order u/s 144C of the Act\npassed.\n24.06.2024\n:\nDRP directions under Section 144C(5) of the Act\nissued.\n31.07.2024\n:\n30.09.2023\n:\nFinal Assessment order under Section 143(3)\nr.w.s144C(13) r.w.s 144B of the Act.\nLimitation for passing the final assessment\norder expired

WIN MEDICARE PRIVATE LIMITED,DELHI vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT (DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 25(1), DELHI), DELHI

In the result, appeal of the Assessee is allowed

Pricing Officer) (TPO\norder)\nTime limit to complete assessment\nproceedings in case of eligible assessee where\nreference to TPO is also made\nTime limit to issue direction for the Dispute\nResolution Panel i.e., within 9 months from\nthe end of the month in which Draft\nAssessment Order is forwarded to eligible\nAssessee\nTime limit to forward the Draft Assessment\nOrder

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

Transfer pricing Officer vide an order dated 31.10.2019, held that since incurring of the said AMP expenses by the assessee had also benefitted the AEs thereby promoting their brands and trademark, the assessee had essentially incurred cost in connection with the services it provided to the AEs under a mutual arrangement, which although not reduced into writing, was ascertainable from

MSD PHARMACEUTICALS PRIVATE LIMITED,NEW DELHI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 16(1), NEW DELHI

In the result, appeals of the Assessee are allowed

pricing order under section 92CA(3) of the Act passed.\n22.09.2023\nDraft assessment order under section 144C of the Act passed.\n30.09.2023\nLimitation for passing the final assessment order expired on\n30.09.2023 i.e. 30 months (18 months+ 12 months) from April 01, 2021\nin view of section 153(1) read with section 153(4) of the Act.\nRefer ground number

AL MAHA FOODS INTERNATIONAL PRIVATE LIMITED,NEW DELHI vs. NATIONAL FACELESS ASSESSMENT CENTRE (JAO - DCIT CIRCLE 1(1), DELHI), NEW DELHI

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalal Maha Foods International Vs National Faceless Private Limited, 1122, Dlf Assessment Centre (Jao- Tower A, Jasola, New Friends Dcit Circle 1(1), C. R. Colony, S.O. Zakir Nagar, Building, I. P. Estate, Delhi Delhi-110025 New Delhi Pan: Aabca8743L Appellant Respondent Assessee By Sh. Salil Kapoor, Adv& Ms. Ananya Kapoor, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 19/01/2026 Date Of Pronouncement 21/01/2026

Pricing the completion limit to complete Officer) (TPO order) of time-limit to assessment complete proceedings assessment 8. The Hon'ble High Court of Madras in the case of Roca Bathroom Products Pvt. Ltd (supra) held that, time limit prescribed u/s 153 of the Act has to be adhered to and that both Section 144C

PEPSICO INDIA HOLDINGS PVT. LTD.,GURGAON vs. ACIT, CENTRAL CIRCLE-7, NEW DELHI

In the result, the appeal of the assessee is allowed and the Stay

Bench: Shri Shamim Yahya & Ms. Astha Chandra[Assessment Year: 2018-19]

AC erred in initiating penalty under section 271AA of the Act. 40. That the NFAC erred in initiating penalty under section 270AA of the Act for non-maintenance of information and documents, after specifically noting that the information and documents prescribed under Rule 10D of the Income- tax Rules, 1962 were duly submitted and placed on record by the Appellant

JOHNSON MATTHEY INDIA PVT. LTD.,DELHI vs. DCIT, CIRCLE-13(1), DELHI

In the result, appeal of the Assessee is allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Assessment Year : 2021-22] Johnson Matthey India Pvt. Vs. Dcit, Ltd., 5Th Floor, C/O Regus Circle-13(1) Business Center, Gurgaon C.R. Building, Delhi Road, South West Delhi- 110037. Pan-Aaacj2919A Appellant Respondent Assessee By Shri Sumit Mangal, Adv. Ms. Radhika Sharma, Adv. Ms. Soumya Pandey, Adv. Revenue By Shri S.K. Jadhav, Cit Dr Date Of Hearing 22.01.2026 Date Of Pronouncement 27.01.2026 Order Per Manish Agarwal, Am : The Captioned Appeal Is Filed By The Assessee Challenging The Final Assessment Order Passed U/S 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income Tax Act, 1961 [“The Act”] Dated 23.10.2024 Pertaining To The Assessment Year 2021-22. 2. During The Course Of Hearing The Bench Has Asked The Assessee To File Specific Ground Of Appeal No.2 As Against General Ground Of Appeal No. 2 Taken. In Compliance, Assessee Vide Application Dt. 12.03.2025 Filed Under Rule 11 Of The Income Tax Appellate Tribunal Rules, 1963 Raised Additional Ground Of Appeal Under. The Additional Ground Of Appeal Taken Reads As Under: Johnson Matthey India Pvt. Ltd. Vs. Dcit

Pricing Officer (TPO), the time) limit available stands extended by another 12 months, and in the present case, the upper time limit for completion of assessment proceedings would expire on 30.09.2021. 18. In the present case, the final assessment order passed by the A.O. under Section 143(3) r.w.s. 144C(13) r.w.s. 144B dated 28.07.2022 is clearly beyond the limitation

TEVA PHARMACEUTICAL & CHEMICAL INDUSTRIES INDIA PRIVATE LIMITED,MUMBAI vs. DCIT, CIRCLE-25(1), DELHI

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalteva Pharmaceutical & Chemical Vs Assessment Unit, Income Industries India Private Limited, Tax Department/Deputy 8Th Floor, C-Wing Time Square, Commissioner Of Income Andherikurla Road, Marol Naka, Tax, Circle 25(1), Opp Mittal Industrial Estate C. R. Building, Delhi- Andheri (E), Mumbai 400059, 110001 Maharashtra, India Pan: Bnspk7225H Appellant Respondent Assessee By Sh. Sachit Jolly, Sr. Adv, Sh. Sohamdua, Adv& Sh. Abhiudaya Shankar Bajpai, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 19/01/2026 Date Of Pronouncement 19/01/2026 Order Per Yogesh Kumar, U.S. Jm: The Captioned Appeal Is Filed By The Assessee Challenging The Final Assessment Order Passed U/S 143(3) R.W.S. 144C(13) R.W.

Pricing Officer under Section 92CA of the Act: consequently, the limitation to pass the Final Assessment Order was extended by 12 months under Section 153(4) of the Act. 4 Objections filed by the Appellant before the 27.10.2023 Dispute Resolution Panel in Form 35A within 30 days of receipt of the draft order. in compliance with Section 144C

SUPERBRANDS LTD (UK),GURGAON vs. DCIT, CIRCLE- 3(1)(2), INTERNATIONAL TAXATION , NEW DELHI

In the result, the appeal is allowed, as indicated above

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Deyआ.अ.सं/.I.T.A No.332/Del/2021 िनधा"रणवष"/Assessment Year: 2016-17 बनाम Superbrands Ltd. (Uk) Dcit C/O Bdo India Llp 1501-1508, Vs. Circle 3(1)(2), Palm Spring Plaza, Sector-54, International Taxation, Golf Course Road, Gurgaon, New Delhi. Haryana. Pan No. Aaics6497G अपीलाथ" Appellant ""यथ"/Respondent

Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any foreign company." 21. A perusal of the aforementioned section shows that it is applicable only in case the assessee is an eligible assessee as defined in Clause (b) of sub-section (15) and the Assessing Officer proposed to make any variation in income or loss returned

MSD PHARMACEUTICALS PRIVATE LIMITED,NEW DELHI vs. DCIT, CIRCLE-16(1), DELHI

In the result, appeals of the Assessee are allowed

pricing order under section 92CA(3) of the Act passed.\n22.09.2023\nDraft assessment order under section 144C of the Act passed.\n30.09.2023\nLimitation for passing the final assessment order expired on\n30.09.2023 i.e. 30 months (18 months+ 12 months) from April 01, 2021\nin view of section 153(1) read with section 153(4) of the Act.\nRefer ground number

ITRON INDIA P.LTD,DELHI vs. DCIT, CIRCLE-10(1), NEW DELHI

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalitron India P. Ltd. Vs The Deputy Commissioner Of Flat No. 507, Income Tax, Circle 10(1), Bhikajicamabhawan, C. R. Building, New Delhi Bhikajicama Place, New Delhi Pan: Aabcs6575L Appellant Respondent Assessee By Sh.Kashish Gupta, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 19/01/2026 Date Of Pronouncement 29/01/2026

pricing order u/s 92CA(3) of the Act 05.05.2021 : Draft assessment order u/s 144C(1) of the Act passed. 15.02.2022 : DRP directions u/s 144C(15) of the Act issued. 31.12.2020 : Limitation for passing the final assessment order -33 months (21 months + 12 Months) from March 2018 in view of section 153(1) read with Section

VIVO MOBILE INDIA PRIVATE LIMITED,GURGAON vs. ACIT, CIRCLE-25(1), DELHI

In the result, appeals of the Assessee are allowed

Pricing Officer\n31.01.2021\n31.07.2021\n31.03.2023\n3.\nDate of draft assessment order issued by Ld.\nAssessing Officer\n21.06.2021\n28.09.2021\n29.09.2023\n4.\nDate of Directions issued by Ld. Dispute\nResolution Panel\n22.03.2022\n22.03.2022\n30.06.2024\n5.\nDate of final assessment order under Section\n143(3) read with Section 144C(13) of the Act\n29.04.2022\n29.04.2022\n31.07.2024\nB.\nCOMPUTATION OF TIME LIMITATION FOR PASSING

EVERSUB INDIA PRIVATE LIMITED ,HARYANA vs. DCIT CIRCLE-22(2), DELHI

In the result, appeals of the Assessee are allowed

pricing order under section 92CA(3) of the Act passed.\n23.09.2021\nDraft assessment order under section 144C(1) of the Act passed.\n18.02.2022\nDRP directions under section 144C(5) of the Act issued.\n31.03.2022\nFinal Assessment order under section 143(3) r.w.s 144C(13) read with\nsection 144B of the Act passed.\n30.09.2021\nLimitation for passing the final assessment order

VALVOLINE CUMMINS PRIVATE LIMITED,DELHI vs. DCIT, CIRCLE-25(1), DELHI

In the result, appeal of the Assessee is allowed

Pricing Officer (TPO), the\ntime) limit available stands extended by another 12 months, and in the present\ncase, the upper time limit for completion of assessment proceedings would expire\non 30.09.2021.\n21\nITA No. 4178/Del/2024\nValvoline Cummins Pvt. Ltd. Vs. DCIT\n18. In the present case, the final assessment order passed by the A.O.\nunder Section 143(3) r.w.s. 144C