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 of the Act. 11. Thus, if, we apply the provisions of section 144C of the Act to the facts of the present appeal, undoubtedly, assessee qualifies as an eligible assessee under sub-section (15)(b)(i) of section 144C of the Act. Further, it is an established fact

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 of the Act. 11. Thus, if, we apply the provisions of section 144C of the Act to the facts of the present appeal, undoubtedly, assessee qualifies as an eligible assessee under sub-section (15)(b)(i) of section 144C of the Act. Further, it is an established fact

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)

transferred to various units including the units eligible for deduction u/s 80 IB/80 IC of the act based upon the sales ratio of all manufacturing units. 4. During assessment year 2005 – 06 to 2011 – 12 assessment orders were passed under the provisions of Section 153A/143 (3) of the act based upon search and seizure operations carried out under the provisions

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

In the result, appeals of the assessees are allowed

Pricing Reference, such time available with the A.O. and T.P.O will be only few\nmonths, effectively scuttling possibility of any meaningful verification or scrutiny of details\nfrustrating very purpose of entire scrutiny assessment related provisions under the I.T. Act.\nSuch a situation will be hit by doctrine of impossibility or doctrine of frustration and courts\nshould avoid any interpretation

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

In the result, appeals of the assessee are allowed

Pricing Reference, such time available with the A.O. and T.P.O will be only few\nmonths, effectively scuttling possibility of any meaningful verification or scrutiny of details\nfrustrating very purpose of entire scrutiny assessment related provisions under the I.T. Act.\nSuch a situation will be hit by doctrine of impossibility or doctrine of frustration and courts\nshould avoid any interpretation

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

In the result, appeals of the assessee are allowed

Pricing Reference, such time available with the A.O. and T.P.O will be only few\nmonths, effectively scuttling possibility of any meaningful verification or scrutiny of details\nfrustrating very purpose of entire scrutiny assessment related provisions under the I.T. Act.\nSuch a situation will be hit by doctrine of impossibility or doctrine of frustration and courts\nshould avoid any interpretation

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

Transfer Pricing Reference, such time available\nwith the A.O. and T.P.O will be only few months, effectively scuttling\npossibility of any meaningful verification or scrutiny of details\nfrustrating very purpose of entire scrutiny assessment related\nprovisions under the I.T. Act. Such a situation will be hit by doctrine\nof impossibility or doctrine of frustration and courts should avoid any\ninterpretation

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

Pricing Reference, such time available with the A.O. and T.P.O will be only few\nmonths, effectively scuttling possibility of any meaningful verification or scrutiny of details\nfrustrating very purpose of entire scrutiny assessment related provisions under the I.T. Act.\nSuch a situation will be hit by doctrine of impossibility or doctrine of frustration and courts\nshould avoid any interpretation

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

Pricing Reference, such time available with the A.O. and T.P.O will be only few\nmonths, effectively scuttling possibility of any meaningful verification or scrutiny of details\nfrustrating very purpose of entire scrutiny assessment related provisions under the I.T. Act.\nSuch a situation will be hit by doctrine of impossibility or doctrine of frustration and courts\nshould avoid any interpretation

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 Reference, such time available with the A.O. and T.P.O will be only few months, effectively scuttling possibility of any meaningful verification or scrutiny of details frustrating very purpose of entire scrutiny assessment related provisions under the I.T. Act. Such a situation will be hit by doctrine of impossibility or doctrine of frustration and courts should avoid any interpretation

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

In the result, appeals of the assessee are allowed

Pricing Reference, such time available with the AO and TPO will be only few\nmonths, effectively scuttling possibility of any meaningful verification or scrutiny of details\nfrustrating very purpose of entire scrutiny assessment related provisions under the I.T. Act.\nSuch a situation will be hit by doctrine of impossibility or doctrine of frustration and courts\nshould avoid any interpretation

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

In the result, appeals of the assessees are allowed

Pricing Reference, such time available with the A.O. and T.P.O will be only few\nmonths, effectively scuttling possibility of any meaningful verification or scrutiny of details\nfrustrating very purpose of entire scrutiny assessment related provisions under the I.T. Act.\nSuch a situation will be hit by doctrine of impossibility or doctrine of frustration and courts\nshould avoid any interpretation

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

In the result, appeals of the assessee are allowed

Pricing Reference, such time available with the A.O. and T.P.O will be only few\nmonths, effectively scuttling possibility of any meaningful verification or scrutiny of details\nfrustrating very purpose of entire scrutiny assessment related provisions under the I.T. Act.\nSuch a situation will be hit by doctrine of impossibility or doctrine of frustration and courts\nshould avoid any interpretation

SHAHNAZ HUSAIN ,DELHI vs. DCIT CIRCLE 28(1), DELHI

Pricing Reference, such time available with the A.O. and T.P.O will be only few\nmonths, effectively scuttling possibility of any meaningful verification or scrutiny of details\nfrustrating very purpose of entire scrutiny assessment related provisions under the I.T. Act.\nSuch a situation will be hit by doctrine of impossibility or doctrine of frustration and courts\nshould avoid any interpretation

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(1) of the Act. The sub-Section\n(1) of Section 144C being

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

Appeals of the assessees are allowed

Pricing Reference, such time available with the A.O. and T.P.O will be only few\nmonths, effectively scuttling possibility of any meaningful verification or scrutiny of details\nfrustrating very purpose of entire scrutiny assessment related provisions under the I.T. Act.\nSuch a situation will be hit by doctrine of impossibility or doctrine of frustration and courts\nshould avoid any interpretation

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

Pricing Reference, such time available with the A.O. and T.P.O will be only few\nmonths, effectively scuttling possibility of any meaningful verification or scrutiny of details\nfrustrating very purpose of entire scrutiny assessment related provisions under the I.T. Act.\nSuch a situation will be hit by doctrine of impossibility or doctrine of frustration and courts\nshould avoid any interpretation

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

Pricing Reference, such time available with the A.O. and T.P.O will be only few\nmonths, effectively scuttling possibility of any meaningful verification or scrutiny of details\nfrustrating very purpose of entire scrutiny assessment related provisions under the I.T. Act.\nSuch a situation will be hit by doctrine of impossibility or doctrine of frustration and courts\nshould avoid any interpretation