COMMISSIONER OF INCOME TAX vs. AMADEUS INDIA PVT LTD

Appeal is dismissed

Section 144C of the said Act. 3. The Transfer Pricing Officer had observed that the assessee had incurred more than

SHAHNAZ HUSAIN,NEW DELHI vs. ASSESSING OFFICER, NATIONAL E- ASSESMENT CENTRE, NEW DELHI

transfer pricing. Having set time limits\nevery step of the way, it does not stand to reason that proceedings on remand to the DRP\nmay be done at leisure sans the imposition of any time limit at all.\n17. Sub-section (13) to section 144C

DCIT, NEW DELHI vs. M/S. BBC WORLD INDIA (P) LTD., NEW DELHI

In the result appeal of the assessee and the learned assessing officer are allowed for statistical purposes

Bench: Shri Kuldip Singh & Shri Prashant Maharishi

section 144C of the act proposing an addition of Rs 22048880/– in pursuance of the direction of the learned dispute resolution panel where the transfer pricing

XANDER ADVISORS INDIA PVT. LTD.,NEW DELHI vs. ACIT, NOIDA

In the result, both the appeals are allowed, as indicated

Bench: Shri G.S. Pannu & Shri Saktijit Dey

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any non-resident not being a company, or any foreign company.” 10. On a reading of sub-section(1) of Section 144C

XANDER ADVISORS INDIA PVT. LTD.,NEW DELHI vs. ACIT, NOIDA

In the result, both the appeals are allowed, as indicated

Bench: Shri G.S. Pannu & Shri Saktijit Dey

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any non-resident not being a company, or any foreign company.” 10. On a reading of sub-section(1) of Section 144C

SEAVIEW DEVELOPERS PRIVATE LIMITED,MUMBAI vs. ACIT, CIRCLE-23(2), NEW DELHI

In the result, appeals of the assessees are allowed

transfer pricing. Having set time limits\nevery step of the way, it does not stand to reason that proceedings on remand to the DRP\nmay be done at leisure sans the imposition of any time limit at all.\n17. Sub-section (13) to section 144C

PR. COMMISSIONER OF INCOME TAX -7 vs. SUMITOMO CORPORATION INDIA (P) LTD.

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE RAVINDER DUDEJA

144C of the Act is tenable or not? Digitally Signed By:KAMLESH KUMAR Signing Date:02.09.2024 17:04:21 Signature Not Verified ITA 52/2023 & other connected matters Page 12 of 74 its order under section 92CA(3) of the Act proposed an upward transfer pricing

THE PR. COMMISSIONER OF INCOME TAX -6 vs. MICROSOFT INDIA ( R & D) PVT. LTD.

Bench: HON'BLE MR. JUSTICE VIPIN SANGHI,HON'BLE MR. JUSTICE SANJEEV NARULA

144C of the Act is tenable or not? Digitally Signed By:KAMLESH KUMAR Signing Date:02.09.2024 17:04:21 Signature Not Verified ITA 52/2023 & other connected matters Page 12 of 74 its order under section 92CA(3) of the Act proposed an upward transfer pricing

THE PR. COMMISSIONER OF INCOME TAX -6 vs. MARUTI SUZUKI INDIA LTD.

Bench: HON'BLE MR. JUSTICE VIPIN SANGHI,HON'BLE MR. JUSTICE SANJEEV NARULA

144C of the Act is tenable or not? Digitally Signed By:KAMLESH KUMAR Signing Date:02.09.2024 17:04:21 Signature Not Verified ITA 52/2023 & other connected matters Page 12 of 74 its order under section 92CA(3) of the Act proposed an upward transfer pricing

JINDAL STEEL & POWER LTD.,NEW DELHI vs. NATIONAL FACELESS CENTRE, NEW DELHI

In the result, appeals of the assessee are allowed

transfer pricing. Having set time limits\nevery step of the way, it does not stand to reason that proceedings on remand to the DRP\nmay be done at leisure sans the imposition of any time limit at all.\n17. Sub-section (13) to section 144C

JINDAL STEEL & POWER LTD.,HISAR vs. ACIT, GURGAON

In the result, appeals of the assessee are allowed

transfer pricing. Having set time limits\nevery step of the way, it does not stand to reason that proceedings on remand to the DRP\nmay be done at leisure sans the imposition of any time limit at all.\n17. Sub-section (13) to section 144C

HUAWEI TELECOMMUNICATIONS (INDIA) COMPANY PRIVATE LIMITED,GURGAON vs. ACIT, CIRCLE-1(1), GURGAON

In the result, all three appeals of the assessee are allowed, and the\nstay application is dismissed as being infructuous

section 144C is a self contained code of assessment and\ntime limits are inbuilt each stage of the procedure contemplated.\nSection 144C envisions a special assessment, one which includes the\ndetermination of Arms Length Price (ALP) of international transactions\nengaged in by the assessee. The DRP was constituted bearing in mind\nthe necessity for an expert body to look into

LI & FUNG (INDIA) P.LTD,NEW DELHI vs. DCIT, CIRCLE-16(1), NEW DELHI

transfer pricing. Having set time limits\nevery step of the way, it does not stand to reason that proceedings on remand to the DRP\nmay be done at leisure sans the imposition of any time limit at all.\n17. Sub-section (13) to section 144C

LI & FUNG (INDIA) PRIVATE LIMITED,NEW DELHI vs. DCIT, CIRCLE-13(1), DELHI

transfer pricing. Having set time limits\nevery step of the way, it does not stand to reason that proceedings on remand to the DRP\nmay be done at leisure sans the imposition of any time limit at all.\n17. Sub-section (13) to section 144C

NOBLE RESOURCES & TRADING INDIA PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

The appeal is allowed with above direction

Bench: Shri Amit Shukla & Shri Prashant Maharishi

transfer pricing officer, The learned AO passed order in terms of section 144C (1) of the act on 07/03/2014 determining

NOBLE RESOURCE & TRADING INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

The appeal is allowed with above direction

Bench: Shri Amit Shukla & Shri Prashant Maharishi

transfer pricing officer, The learned AO passed order in terms of section 144C (1) of the act on 07/03/2014 determining

MUFG BANK LTD,NEW DELHI vs. ACIT, CIRCLE 2(2)(1), INTERNATIONAL TAXATION, NEW DELHI

In the result, all five appeals of the assessee are allowed

transfer pricing. Having set time limits every step of the way, it does not stand to reason that proceedings on remand to the DRP may be done at leisure sans the imposition of any time limit at all.\n17. Sub-section (13) to section 144C

COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION- 2, NEW DELHI vs. HYUNDAI ROTEM COMPANY

The appeal is dismissed

Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR

Transfer Pricing Officer passed under sub-section (3) of Section 92-CA; and (ii) any non-resident not being a company, or any foreign company.‖ 17. As is manifest from a reading of sub-section (13) of Section 144C