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, in my view, imposes a restriction on the Assessing\nOfficer and denies him the benefit

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

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

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

In the result, appeals of the Assessee are allowed

Transfer pricing order under section 92CA(3) of the Act passed.\nDraft assessment order under section 144C of the Act passed

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

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any foreign company.]” 15. A plain reading of Section indicates that it is obligatory on the part of the AO to forward a draft Assessment Order as per the provisions of Section 144C

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any foreign company.]” 15. A plain reading of Section indicates that it is obligatory on the part of the AO to forward a draft Assessment Order as per the provisions of Section 144C

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any foreign company.]” 15. A plain reading of Section indicates that it is obligatory on the part of the AO to forward a draft Assessment Order as per the provisions of Section 144C

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any foreign company.]” 15. A plain reading of Section indicates that it is obligatory on the part of the AO to forward a draft Assessment Order as per the provisions of Section 144C

DCIT, NEW DELHI vs. M/S WICKWOOD DEVELOPMENT LTD.,, NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any foreign company.]” 15. A plain reading of Section indicates that it is obligatory on the part of the AO to forward a draft Assessment Order as per the provisions of Section 144C

DCIT, NEW DELHI vs. ISERVICES INVESTMENTS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any foreign company.]” 15. A plain reading of Section indicates that it is obligatory on the part of the AO to forward a draft Assessment Order as per the provisions of Section 144C

LINTEC INDIA PRIVATE LIMITED,SOUTH DELHI, DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 13(1), OFFICE OF DCIT, CR BUILDING, DELHI,

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwallintec India Private Limited Vs The Deputy Commissioner Of 14Th Floor, Eros Corporate Tower, Income Tax, Circle 13(1), Nehru Place, South Delhi, Delhi Office Of The Dcit, C. R. 110019, Building, Delhi Pan: Aaccl23772F Appellant Respondent Assessee By Sh. Supriya Mehta, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 19/01/2026 Date Of Pronouncement 21/01/2026

transfer July 30, July 31, Yes pricing order u/s 92CA(3) of 2023 2023 the Act 2 Date of passing of the draft September - Yes assessment order u/s 143(3) 27, 2023, r.w. Section 144C

DCIT, NEW DELHI vs. M/S. NEWBURY HOLDING TWO 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

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, in my view, imposes a restriction on the Assessing\nOfficer and denies him the benefit

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

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

TRAVELPORT LP,GEORGIA USA vs. DCIT, INTERNATIONAL TAXATION CIRCLE-3(1)(1), NEW DELHI

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

Bench: Shri N.K. Billaiya & Shri Anubhav Sharma

144C of the Act defines eligible assessee as under:–“(15) For the purpose of this section,–(a) ........(b) “eligible assessee” means,– (i) any person in whose case the variation referred to in sub–section (1) arises as a consequence of the order of the Transfer Pricing Officer passed under sub–section (3

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, in my view, imposes a restriction on the Assessing\nOfficer and denies him the benefit