MUFG BANK,LTD (EARLIER KNOWN AS THE BANK OF TOKYO MITSUBISHI UFJ LTD.),NEW DELHI vs. ACIT, CIRCLE-2(2)(1) INT. TAXATION, DELHI

In the result, the appeal of the assessee is allowed in above terms

Bench: Shri Pradip Kumar Kedia & Shri Narender Kumar Choudhry

Section 133(6) has been obtained for determining the ALP of the impugned transaction, thereby, violating the principles of natural justice; and (d) Not issuing the show cause notice proposing transfer pricing

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

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

6 D of the OECD Guidelines deals with 'Marketing activities undertaken by enterprises not owning trademarks or trade names'. It contains a discussion on promotion of trade marks by distributors of branded goods. It acknowledges the difficulties in determining the extent to which the expenses have contributed to the success of a product

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

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

6 D of the OECD Guidelines deals with 'Marketing activities undertaken by enterprises not owning trademarks or trade names'. It contains a discussion on promotion of trade marks by distributors of branded goods. It acknowledges the difficulties in determining the extent to which the expenses have contributed to the success of a product

DCIT, NEW DELHI vs. FIS GLOBAL BUSINESS SOLUTION INDIA (P) LTD., NEW DELHI

In the result, both appeals of the revenue stand dismissed and both Cos are allowed as above

Bench: SHRISUDHIR KUMAR (Judicial Member), SHRI AVDHESH KUMAR MISHRA (Accountant Member)

section 133(6) of the Act, recasted the fianacials for 12 months. It was argued by the Ld. Counsel that such exercise was not justified as the financials of Megasoftcould not be reliably recasted. Hence, the Ld. CIT(A) had righly held Megasoft as non-suitable comparable. 7. The Ld. Counsel further contended that there was no merit

DCIT, NEW DELHI vs. M/S. FIS GLOBAL BUSINESS SOLUTIONS INDIA PVT. LTD., NEW DELHI

In the result, both appeals of the revenue stand dismissed and both Cos are allowed as above

Bench: SHRI AVDHESH KUMAR MISHRA (Accountant Member)

section 133(6) of the Act, recasted the fianacials for 12 months. It was argued by the Ld. Counsel that such exercise was not justified as the financials of Megasoftcould not be reliably recasted. Hence, the Ld. CIT(A) had righly held Megasoft as non-suitable comparable. 7. The Ld. Counsel further contended that there was no merit

ACE CABS LIMITED,DELHI vs. ACIT, CIRCLE-1(2), DELHI, C R BUILDING

In the result, appeal filed by the assessee is allowed

Bench: Shri Saktijit Dey, Hon’Ble & Shri S.Rifaur Rahmanace Cabs Limited, Vs. Acit, Circle 1 (2), 562, Silver Oak Lane, Delhi. M.G. Road, Ghitorni, Delhi – 110 030. (Pan : Aaica4494R) (Appellant) (Respondent) Assessee By : Shri Gaurav Jain, Advocate Ms. Bharti Sharma, Advocate Revenue By : Shri Kanv Bali, Sr. Dr Date Of Hearing : 23.07.2024 Date Of Order : 04.10.2024 Order Per S.Rifaur Rahman,Am: 1. This Appeal Has Been Filed By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals), New Delhi [“Ld. Cit(A)”, For Short]/ National Faceless Appeal Centre (Nfac) Dated 12.12.2023 For The Assessment Year 2017-18. 2. The Assessee Submitted An Application Under Rule 29 Of The Itat Rules For Admitting The Additional Evidences & The Contents Thereof Are Reproduced Below:-

Section 68 of the Act, based on the following allegations: 5 a) M/s Click Cab Technology LLP lacks the creditworthiness to make such a big investment on the ground that its statement of income & expenditure and ITR showed Nil Income and also due to non-compliance of notices issued u/s 133(6) of the Act. The AO failed to appreciate

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)

6 of the Revenue is in respect of transfer pricing adjustment in respect benchmarking of interest received on foreign currency loan. The Co-ordinate Bench of the Tribunal in assessee’s own case for Assessment Year 2012-13 while dealing with the very same issue has held as under:- “ 44. Ground number 15 of the appeal is with respect

ACIT, NEW DELHI vs. M/S. DEVINE INFRACON PVT. LTD., NEW DELHI

Bench: M Balaganesh, Accontant Member & Ms Madhumita Royassessment Year: 2010-11 The Assistant Vs. M/S Divine Infracon Commissioner Of Income Private Limited, Plot Tax, Central Circle-09, No. 4, Sector-13, Jhandewalan, New Delhi, Dwarka City Centre, Room No.357, Ara Centre, Dwarka, New Delhi- E-2, Jhandewalan 110075 Extension, New Delhi Pan :Aaccd4476A (Appellant) (Respondent) Assessee By Shri Salil Aggarwal, Sr, Advocate Department By Shri T James Singson, Cit, Dr

section 133 (6) of the Act, moreover, the fact the lender company was subsequently purchased by the various members of Jagat Group is an irrelevant and extraneous consideration as it is a separate transaction altogether and learned officer cannot doubt the said transaction as had been held in CIT vs. Walchand & Co. (P) Ltd. reported in 65 ITR 381 stating

DCIT, CENTRAL CIRCLE-20, DELHI vs. LOTUS HERBALS PVT. LTD, DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

133(6) n. Certificate of turnover 3. Accordingly, in light of facts and decision as above, your honor is most respectfully requested to decide the appeal as per the provisions of law, subject to your honor’s satisfaction. Yours faithfully. ANSHUL Deputy Commissioner of Income Tax, Central Circle-20, Delhi 14. Ld. CIT(A) after considering the replies

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

133(6) n. Certificate of turnover 3. Accordingly, in light of facts and decision as above, your honor is most respectfully requested to decide the appeal as per the provisions of law, subject to your honor’s satisfaction. Yours faithfully. ANSHUL Deputy Commissioner of Income Tax, Central Circle-20, Delhi 14. Ld. CIT(A) after considering the replies

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

133(6) n. Certificate of turnover 3. Accordingly, in light of facts and decision as above, your honor is most respectfully requested to decide the appeal as per the provisions of law, subject to your honor’s satisfaction. Yours faithfully. ANSHUL Deputy Commissioner of Income Tax, Central Circle-20, Delhi 14. Ld. CIT(A) after considering the replies

DCIT, CENTRAL CIRCLE-20, NEW DELHI vs. LOTUS HERBALS P.LTD, DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

133(6) n. Certificate of turnover 3. Accordingly, in light of facts and decision as above, your honor is most respectfully requested to decide the appeal as per the provisions of law, subject to your honor’s satisfaction. Yours faithfully. ANSHUL Deputy Commissioner of Income Tax, Central Circle-20, Delhi 14. Ld. CIT(A) after considering the replies

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

133(6) n. Certificate of turnover 3. Accordingly, in light of facts and decision as above, your honor is most respectfully requested to decide the appeal as per the provisions of law, subject to your honor’s satisfaction. Yours faithfully. ANSHUL Deputy Commissioner of Income Tax, Central Circle-20, Delhi 14. Ld. CIT(A) after considering the replies

COSMIC INFORMATICS PVT. LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE - 2, NEW DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

133(6) n. Certificate of turnover 3. Accordingly, in light of facts and decision as above, your honor is most respectfully requested to decide the appeal as per the provisions of law, subject to your honor’s satisfaction. Yours faithfully. ANSHUL Deputy Commissioner of Income Tax, Central Circle-20, Delhi 14. Ld. CIT(A) after considering the replies

COSMIC INFORMATICS PVT. LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE - 2, NEW DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

133(6) n. Certificate of turnover 3. Accordingly, in light of facts and decision as above, your honor is most respectfully requested to decide the appeal as per the provisions of law, subject to your honor’s satisfaction. Yours faithfully. ANSHUL Deputy Commissioner of Income Tax, Central Circle-20, Delhi 14. Ld. CIT(A) after considering the replies

LG ELECTRONICS INDIA PRIVATE LIMITED ,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

LG ELECTRONICS INDIA PVT. LTD.,NEW DELHI vs. ADDL. CIT, SPECIAL RANGE- 5, NEW DELHI

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

DCIT, CIRCLE-13(1), NEW DELHI vs. LG ELECTRONICS INDIA PVT. LTD., DELHI

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent