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

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

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

SICPA INDIA PRIVATE LIMITED,NEW DELHI vs. ACIT, CIRCLE-23(2), 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

MUFG BANK LTD,NEW DELHI vs. ASSISTANT COMMISSIONER OF INCOME-TAX, 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

JINDAL STEEL & POWER LTD.,NEW DELHI vs. ACIT, CIRCLE- 1(1), 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

SHAHNAZ HUSAIN ,DELHI vs. DCIT CIRCLE 28(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

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

SOFTWARE ONE INDIA P.LTD,NEW DELHI vs. ACIT, CIRCLE-22(2), NEW DELHI

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

CRM SERVICES INDIA P.LTD,NEW DELHI vs. DCIT, CIRCLE-4(2), 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

RENEW SOLAR ENERGY (TN) PRIVATE LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 19(1), 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

STERIA (INDIA) LTD.,NOIDA vs. NEAC, 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