(Now known as Sony India Limited)

Sections (1) and (2) to Section 92C are applicable to the assessed, as well as the Assessing Officer invoking power under Sub-Section (3) to Section 92C of the Act. As noted above, sub-section (2) to Section 92C stipulates that most appropriate method, out of the methods specified in sub-section (1) shall be applied to determine

MICROSOFT CORPORATION (INDIA) PRIVATE LIMITED,NEW DELHI vs. DCIT, CIRCLE-16(1), NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh & Shri Yogesh Kumar Usmicrosoft Corporation (India) Vs. Dcit, Pvt. Ltd, Circle-16(1), 807, New Delhi House, New Delhi Barakhamba Road, New Delhi (Appellant) (Respondent) Pan: Aaacm5586C Assessee By : Shri Nageswar Rao & Parth, Adv Revenue By: Shri Rajesh Kumar, Cit(Dr) Date Of Hearing 22/02/2024 Date Of Pronouncement 28/02/2024

pricing, data analytics, management or any other technical matter under this Act or an agreement entered into under section 90 or 90A, which may be required in a particular case or a class of cases, under this section and the term "technical unit", wherever used in this section, shall refer to an Assessing Officer having powers so assigned

ACIT, NEW DELHI vs. M/S. KCT PAPERS LTD., NEW DELHI

In the result, grounds raised by the revenue are dismissed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharmaacit, Circle 5 (1) Vs. M/S. Kct Papers Limited, New Delhi. Thapar House, 124, Janpath, New Delhi – 110 001. (Pan : Aacck4937D) (Appellant) (Respondent) Assessee By : Shri Rohit Jain, Advocate Shri Deepesh Jain, Advocate Shri Tavish Verma, Advocate Revenue By : Shri Kailash Dan Ratnoo, Cit Dr Date Of Hearing : 10.09.2025 Date Of Order : 05.12.2025 O R D E R Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax (Appeals)-Viii, New Delhi [Hereinafter Referred To As ‘Ld. Cit (A)] Dated 21.03.2014For Assessment Year 2008-09. 2. Brief Facts Of The Case Are, The Assessee Company Belongs To The Thapar Group Established By Late Lala Karam Chand Thapar. There Was A Family Settlement Between The Various Constituents Of The Karam Chand Thapar Family As A Result Of Which Revenue-Organization/Restructuring Of The Group Dated 27Th April, 2001. The Re April, 2001. The Re-Organization Of The Group Companies & Trusts Organization Of The Group Companies & Trusts Was Made Into Four Groups, As Under, Each Headed By The Sons Of Late Lala Was Made Into Four Groups, As Under, Each Headed By The Sons Of Late Lala Was Made Into Four Groups, As Under, Each Headed By The Sons Of Late Lala K.C. Thapar. The Family Tree Of Karam Chand T K.C. Thapar. The Family Tree Of Karam Chand Thapar Family Is Explained As Hapar Family Is Explained As Under In The Form Of A Diagrammatic Chart: Under In The Form Of A Diagrammatic Chart:

section 2(19AA) of the Act. In case any further detail/ document is required, the assessee shall be pleased to submit the same. 13. Considering the aforesaid factual matrix and having regard to the legal and factual aspects placed on record vide earlier submissions, it is patently clear that schemes of amalgamation and demerger satisfied all the relevant conditions provided

DCIT(E), CIRCLE-1(1), NEW DELHI vs. INDIAN GRAMEEN SERVICES, NEW DELHI

In the result, the appeal of the Revenue in ITA No

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

price was such as to shock the conscience of the court, it was not possible to hold that the transaction was otherwise than for adequate consideration. This is a test which the rent under consideration had to meet. 4.1.9 In the case of Ram Bhawan Dharamsala v. State of Rajasthan [(2002) 258 ITR 725 (Raj.)], it has been held that

ARIBA INDIA PRIVATE LIMITED,DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, DELHI

In the result, appeal of the assessee is allowed

Bench: SHRI YOGESH KUMAR U.S (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

H” BENCH: NEW DELHI BEFORE SHRI YOGESH KUMAR U.S, JUDICIAL MEMBER & SHRI MANISH AGARWAL, ACCOUNTANT MEMBER Ariba India Private Limited, ACIT, 6th Floor, MGF Corporate Park, Circle-1(1), MGF Metropolitan Mall, Saket Vs. CR Building, ITO, District Centre, South Delhi, IP Estate, New Delhi-110017. New Delhi-110002. PAN-AAACF4192P (Appellant) (Respondent) Assessee by Ms. Reema Grewal, CA Department

FRESENIUS KABI ONCOLOGY LTD,NEW DELHI vs. ITO, WARD-9(3), NEW DELHI

In the result appeal of the assessee is allowed

Bench: Shri Prakash Chand Yadav & Shri Manish Agarwalfresenius Kabi Oncology Ltd. Income Tax Officer, B-310, Som Dutt Chamber, Ward-9(3), Bhikaji Cama Place, Vs. New Delhi. New Delhi-110066. Pan-Aabcd7720L (Appellant) (Respondent)

H’: NEW DELHI BEFORE SHRI PRAKASH CHAND YADAV, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER Fresenius Kabi Oncology Ltd. Income tax Officer, B-310, Som Dutt Chamber, Ward-9(3), Bhikaji Cama Place, Vs. New Delhi. New Delhi-110066. PAN-AABCD7720L (Appellant) (Respondent) Assessee by Shri Aditya Vohra, Adv. Shri Arpit Goyal, CA and Ms. Mansha Bhalla, CA Department

HEWITT ASSOCIATES (INDIA) PVT. LTD.,GURGAON vs. ACIT, NEW DELHI

In the result, the appeal of the assesee is treated as allowed for statistical purposes

Bench: Shri R.K. Panda & Ms. Astha Chandraasstt. Year : 2007-08

Pricing Review for the FY ended 31.03.2007 (pages 643-648, 653-654 of Paper Book). He further submitted that TNMM applied by the TPO which has been accepted by the assessee takes care of minor differences in functional profile etc. and hence this company be retained as a comparable company. 14.5 We have heard the Ld. Representatives of both

ROLLS-ROYCE INDIA PRIVATE LIMITED ,DELHI vs. DCIT TP 3(2)(1), DELHI

The appeal is allowed as indicated above

Bench: Shri Ramit Kochar & Shri Sudhir Pareek

H’: NEW DELHI) BEFORE SHRI RAMIT KOCHAR, ACCOUNTANT MEMBER AND SHRI SUDHIR PAREEK, JUDICIAL MEMBER ITA No:- 252/Del/2022 (Assessment Year- 2017-18) Rolls Royce India Pvt. DCIT, Ltd.,2nd floor, Birla Tower Vs. TP 3(2)(1), (West),25 Barakhamba Delhi. Road, New Delhi-110001. PAN No: AABCR5277Q APPELLANT RESPONDENT Assessee by : Shri Nikhil Tiwari, Adv. Revenue by : Shri

VACHASPATI SHARMA,GURGAON vs. ITO WARD -4(1), GURGAON

In the result, the appeal of the assessee is dismissed

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2019-20 Vachaspati Sharma Vs Ito Village – Hayatpur Garhi Ward-4 Harsaru, Hayatpur, Gurgaon Gurgaon Pan No.Fnqps2021R (Appellant) (Respondent) Appellants By Sh. Suraj Bhan Nain, Advocate Sh. K.L. Pahwa, Advocate Respondent By Ms. Sapna Bhatia, Cit Dr Date Of Hearing: 11/09/2024 Date Of Pronouncement: 21/11/2024 Order Sh. Sudhir Kumar, Jm :

H) the Hon’ble Punjab & Haryana High Court (Jurisdictional High Court) held that ;- 27. The interpretation aforesaid has the legislative acceptance by way of incorporation of Section 145A(b) and 56(1) (vii) w.e.f. 1-4-2010 by Finance (No. 2) Act, 2009 whereby now irrespective of system of accountancy being followed by the assessee, the interest on enhanced compensation

L.S CABLE INDIA PVT LTD ,REWARI vs. DCIT, CIRCLE13(1), NEW DELHI

In the result, appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2018-19] L S Cable India Pvt.Ltd., Vs Dcit, Plot No.28-31, Sector-5, Cirlce-13(1), Phase-Ii, Hsiidc Gc Bawal, New Delhi Rewari, Haryana-23501. Pan-Aabcl3621Q Appellant Respondent Appellant By Shri Gaurav Garg, Ca Respondent By Shri S.K.Jhadav, Cit Dr Date Of Hearing 01.04.2025 Date Of Pronouncement 29.05.2025

H” BENCH: NEW DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER & SHRI MANISH AGARWAL, ACCOUNTANT MEMBER [Assessment Year : 2018-19] L S Cable India Pvt.Ltd., vs DCIT, Plot No.28-31, Sector-5, Cirlce-13(1), Phase-II, HSIIDC GC Bawal, New Delhi Rewari, Haryana-23501. PAN-AABCL3621Q APPELLANT RESPONDENT Appellant by Shri Gaurav Garg, CA Respondent by Shri S.K.Jhadav, CIT DR Date

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

H’ NEW DELHI)\nBEFORE YOGESH KUMAR U.S., JUDICIAL MEMBER\nAND\nSHRI MANISH AGARWAL, ACCOUNTANT MEMBER\nITA No. 4563/DEL/2024 (A.Y. 2020-21)\nClass Agricultural Machinery Vs The Deputy Commissioner\nPrivate Limited\nof Income Tax, Circle 4(2),\nFloat No. M, First Floor, Sagar\nC. R. Building,\nApartment 6, Tilak Marg,\nindraprastha Marg, I. P.\nCentral Delhi-110001, New\nEstate, New Delhi

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.

H. Approach of Hon'ble ITAT Delhi 28. It is respectfully submitted that the Hon'ble ITAT, Delhi, has consistently adopted a prudent and institutionally sound approach in matters where the assessee raises the preliminary issue of limitation involving the interplay of sections 144C and 153, by adjourning such matters sine die/deferring adjudication, noting that the controversy is pending consideration

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

Transfer 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.\n18. In the present case, the final assessment order passed by the A.O.\nunder Section 143(3) r.w.s. 144C(13) r.w.s. 144B dated 28.07.2022 is\nclearly beyond

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

h e p ti n T a b 2 3 1 6 I n n o v a t i o n s P v t . 2 1 0 x 0 . 0 2 5 P S L t d . 1 1 0 0 0 4 2

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

In the result, appeals of the Assessee are allowed

H’ NEW DELHI)\nBEFORE YOGESH\nKUMAR U.S., JUDICIAL MEMBER\nAND\nSHRI MANISH AGARWAL, ACCOUNTANT MEMBER\nITA No. 7833/DEL/2017 (A.Y. 2013-14)\nBaxter India Pvt. Ltd.\n2nd Floor, Tower C, Building\nNo. 8, DLF Cyber City, DLF\nPhase-II, Gurgaon\nPAN: AAACB3906F\nAppellant\nVs ACIT\nCircle 4 (1)\nC. R. Building,\nNew Delhi\nRespondent\nITA No. 1360/DEL/2022 (A.Y. 2017-18)\nITA

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 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. 2 2. Brief facts of the case are, assessee revised the return of income for the AY 2018-19 on 29.03.2019 declaring total income of Rs.Nil

XL INDIA BUSINESS SERVICES PRIVATE LIMITED,DELHI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, NEW DELHI

In the result, appeal of the Assessee is allowed

H’ NEW DELHI)\nBEFORE YOGESH KUMAR U.S., JUDICIAL MEMBER\nAND\nSHRI MANISH AGARWAL, ACCOUNTANT MEMBER\nITA No. 4332/DEL/2024 (A.Y. 2020-21)\nXL India Business Services Vs The Assistant\nPrivate Limited\nCommissioner of Income\nFF 101, First Floor, Building No.\nTax, Circle 25(1), C. R.\nG-11, Sarines Sonia Sadan,\nBuilding, I. P. Estate, New\nCommunity Centre, VikasPuri,\nDelhi\nWest

DEEPAK KATHARI,KANPUR vs. ACIT, CC-5, NEW DELHI

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

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI VIMAL KUMAR (Judicial Member)

price before and after the issue. PCIT Vs Dr. Ranjan Pai (Karnataka High Court) Section 56of the Income-tax Act, 1961 - Income from other sources - Chargeable as (Gift) - Assessment year 2012-13 - Bonus shares can inadequate consideration calling for application of sub-clause (c) of clause (vii) of section 56(2) [In favour of assessee] An assessee who received bonus