COMMISSIONER OF INCOME TAX vs. AMADEUS INDIA PVT LTD

Appeal is dismissed

144C of the said Act. 3. The Transfer Pricing Officer had observed that the assessee had incurred more than the normal sales and marketing expenses to build the “Amadeus” brand in India which was owned by Amadeus Spain. According to the Transfer 2011:DHC:6027-DB ITA 938/11 Page 3 of 20 Pricing Officer, the assessee should have been reimbursed

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

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

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

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

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

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

144C(13) r.w.s. 144B of the Act. In\ncase the final assessment order passed by the A.O. under Section 143(3) r.w.s.\n144C(13) r.w.s. 144B is beyond the upper time limit provided under Section 153(1)\nand Section 153(4) of the Act, then the said order is beyond the limitation\nprescribed and liable to be quashed

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

THE BANK OF TOKYO MISTUBISHI UFJ LTD.,NEW DELHI vs. DCIT, CIRCLE- 3(1)(1), INTERNATIONAL TAXATION, NEW DELHI

In the result, appeal of the assessee is allowed and appeal of the Revenue is\ndismissed

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

DENSO INDIA PVT. LTD.,NEW DELHI vs. JCIT, 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

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)

Transfer Pricing Officer passed under sub-section (3) of section 92-CA; and (ii) any foreign company.’ 9. A reference is also made to the provisions of section 144B relating to the faceless assessment pertaining to the assessment completed in case of eligible assessee u/s 144C of the Act, which are as under: Ariba India Pvt.Ltd. vs. ACIT “144B.Faceless Assessment

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

GIESECKE & DEVRIENT MS INDIA PVT. LTD.,MUMBAI vs. ACIT (OSD), 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

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

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

JINDAL STEEL & POWER LTD.,HISAR vs. DCIT, CIRCLE- 1(1), GURUGRAM

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

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.

Transfer Pricing Officer (TPO), the time) limit available stands extended by another 12 months, and in the present case, the upper time limit for completion of assessment proceedings would expire on 30.09.2021. 18. In the present case, the final assessment order passed by the A.O. under Section 143(3) r.w.s. 144C(13

LUFTHANSA TECHNIK SERVICES INDIA PVT. LTD.,NEW DELHI vs. ACIT, 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