COMMISSIONER OF INCOME TAX vs. AMADEUS INDIA PVT LTD

Appeal is dismissed

d) the assessee has failed to furnish, within the specified time, any information or document which he was required to furnish by a notice issued under sub- section (3) of section 92D, the Assessing Officer may proceed to determine the arm’s length price in relation to the said international transaction in accordance with sub-sections (1

MANKIND PHARMA LIMITED,DELHI vs. DCIT, CIRCLE-1(1)(1), MEERUT

In the result, the additional Ground No

Bench: Shri Challa Nagendra Prasad & Shri Pradip Kumar Kedia

D E R PER PRADIP KUMAR KEDIA-AM: The captioned appeal has been filed at the instance of the assessee against the final assessment order dated 28.07.2022 passed under Section 143(3) r.w. Section 144C(13) r.w. Section 144B of the Income Tax Act (in short ‘the Act’) in pursuance of directions issued by Dispute Resolution Panel (DRP) dated

COMMISSIONER OF INCOME TAX vs. MENTOR GRAPHICS (NOIDA) PVT.LTD

The appeal is allowed

d) set out in sub-section (3) of section 92C existed and then he could proceed to determine the arm’s length price in relation to the international transactions in question in accordance with sub-sections 2013:DHC:1680-DB ITA No. 1114/2008 Page 12 of 26 (1) and (2) of section 92C on the basis of such material

DCIT, CIRCLE- 16(2), NEW DELHI vs. MENETA AUTOMOTIVE COMPONENTS PVT. LTD., NEW DELHI

In the result, the appeal of the Revenue is dismissed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

d 92A taxpayer taxpayer by the by TPO the A.O. A.O. payer section 92B enterprise Transfer and the Pricing nature assessment country in Officer of year which it under business is resident section 92CA (3) ANNEXURE II Order under section 120, read with section 92CA of the Income-tax Act, 1961, dated April, 2003 In exercise of the power conferred

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 of jurisdiction to the JAO in the impugned assessment order and/ or any other communication to the appellant. 35. Being so, the impugned order passed by Asst. Commissioner of Income Tax, Circle 7(1) and not by NFAC is, in our respectful submissions, beyond jurisdiction, illegal and bad in law being passed by officer not having jurisdiction. Re (d

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

The appeals are allowed in the above terms, but with no orders as to costs

D G E M E N T % 11.12.2015 Dr. S.Muralidhar,J.: Introduction 1. These are two appeals by the Assessee, Maruti Suzuki India Ltd. (‘MSIL’), under Section 260A of the Income Tax Act, 1961 (‘Act’). ITA 2015:DHC:10110-DB ITA Nos.110/2014 & 710/2015 Page 2 of 45 No.110 of 2014 is directed against an order dated 2nd August 2013 passed

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

The appeals are allowed in the above terms, but with no orders as to costs

D G E M E N T % 11.12.2015 Dr. S.Muralidhar,J.: Introduction 1. These are two appeals by the Assessee, Maruti Suzuki India Ltd. (‘MSIL’), under Section 260A of the Income Tax Act, 1961 (‘Act’). ITA 2015:DHC:10110-DB ITA Nos.110/2014 & 710/2015 Page 2 of 45 No.110 of 2014 is directed against an order dated 2nd August 2013 passed

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)

D 2 2163283/- at rate of 3% per annum inclusive of LIBOR rate applicable on loan. However learned transfer pricing officer determine ALP at INR 8 1714969/- and thereby addition of INR 59551686 has been made. He further submitted that learned transfer-pricing officer has used CUP method for benchmarking international transaction by adopting interest rate at rate

KUNSHAN Q TECH MICROELECTRONICS (INDIA) PVT. LTD.,UTTAR PRADESH vs. DCIT, CENTRAL CIRCLE-30, DELHI

pricing adjustment particularly when all the requisite details & documents were placed before the authorities with regard to purchase of capital assets and hence, the entire erroneous addition needs to be deleted.\n13. That on the facts, law and in the circumstances of the case, the Ld. AO as well as the Ld. DRP has erred in law in making addition

JAN KALYAN SAMITI,GHAZIABAD vs. ITO WARD EXEMPTION, GHAZIABAD

In the result appeal filed by the assessee is allowed

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhanjan Kalyan Samiti Vs. Ito Ward Exemption A-48, Chander Nagar Sahibabad, Ghaziabad Ghaziabad 201002 (Pan: Aaatj5583B)

D E R PER S. RIFAUR RAHMAN, ACCOUNTANT MEMBER : 1. This appeal is filed by the assessee against the order of ld. Commissioner of Income-tax (Appeals)/ National Faceless Appeal Centre (NFAC), Delhi (hereinafter referred to ‘ld. CIT (E)’) dated 17.07.2025 for Assessment Year 2015-16. 2. Brief facts of the case are, assessee filed return of income declaring

DCIT, NEW DELHI vs. M/S WICKWOOD DEVELOPMENT LTD.,, NEW DELHI

In the result, the Cross Objections of the assessees are\nallowed and consequently the appeals of the revenue are liable\nto be dismissed

Transfer Pricing Officer passed\nunder sub-section (3) of section 92CA; and\n(ii) any foreign company.]\"\n15. A plain reading of Section indicates that it is obligatory on\nthe part of the AO to forward a draft Assessment Order as per\nthe provisions of Section 144C(1) of the Act. The sub-Section\n(1) of Section 144C being

TELETUBE ELECTRONICS LTD

The appeal of the Assessee is allowed

price of the asset was fixed it was between the parties to decide about the terms of payments which unless prohibited in the statute cannot be gone behind. 15. On an examination of the lease deed, the ITAT held that the leasehold rights in the business assets were sold for Rs.20.729 crore which was undoubtedly agreed to be paid

TELETUBE ELECTRONICS LTD

The appeal of the Assessee is allowed

price of the asset was fixed it was between the parties to decide about the terms of payments which unless prohibited in the statute cannot be gone behind. 15. On an examination of the lease deed, the ITAT held that the leasehold rights in the business assets were sold for Rs.20.729 crore which was undoubtedly agreed to be paid

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

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

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (j) any foreign company. 45.3 Further, consequential amendments have been made – (i) in sub-section (1) of section 131 so as to provide that the “Dispute Resolution Panel” shall have the same powers as are vested in a Court under the Code of Civil Procedure

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

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

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (j) any foreign company. 45.3 Further, consequential amendments have been made – (i) in sub-section (1) of section 131 so as to provide that the “Dispute Resolution Panel” shall have the same powers as are vested in a Court under the Code of Civil Procedure

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

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

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (j) any foreign company. 45.3 Further, consequential amendments have been made – (i) in sub-section (1) of section 131 so as to provide that the “Dispute Resolution Panel” shall have the same powers as are vested in a Court under the Code of Civil Procedure

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

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

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (j) any foreign company. 45.3 Further, consequential amendments have been made – (i) in sub-section (1) of section 131 so as to provide that the “Dispute Resolution Panel” shall have the same powers as are vested in a Court under the Code of Civil Procedure

DCIT, NEW DELHI vs. M/S WICKWOOD DEVELOPMENT LTD.,, NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

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

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (j) any foreign company. 45.3 Further, consequential amendments have been made – (i) in sub-section (1) of section 131 so as to provide that the “Dispute Resolution Panel” shall have the same powers as are vested in a Court under the Code of Civil Procedure