DCM SHRIIRAM LTD.,NEW DELHI vs. ADDL.CIT, SPECIAL RANGE- 3 , NEW DELHI

In the result appeal of assessee is partly allowed

Bench: Shri Kul Bharat & Shri Prashant Maharishi(Through Video Conferencing)

price for transfer of steam at NIL and, in effect, disregarding the entire transaction- on the following grounds by incorrectly holding that:-  The cost of electricity absorbs the entire cost of production of steam.  Steam is only a by-product of the process of manufacturing power, ignoring the fact that steam is joint product of power plants.  The entire cost

M/S. BG EXPLORATION & PRODUCTION INDIA LTD.,MUMBAI vs. JCIT, DEHRADUN

Bench: Shri I. C. Sudhir & Shri Prashant Maharishibg Exploration & Production Jcit, India Ltd, International Taxation, Bg House, Dehradun Vs. Lake Boulevard Road, Hiranandani Business Park, Powai, Mumbai Pan:Aaace4569K (Appellant) (Respondent) Dcit, Bg Exploration & Production International Taxation, India Ltd, Bg House, Lake Dehradun Boulevard Road, Hiranandani Vs. Business Park, Powai, Mumbai Pan: Aaace4569K (Appellant) (Respondent)

section 92CA of the Income Tax Act of Rs. 8018048/– . Assessee objected to the comparables before the Ld. Dispute Resolution Panel, however, the contention of the Assessee was B G Exploration & Production India Limited V DCIT ITA No 1170/Del/2015 DCIT V B G Exploration & Production India Limited ITA No 1581/Del/2015 AY 2010-11 rejected holding that the Ld. Transfer Pricing

RANBAXY LABORATORIES LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, we direct the AO to reduce the book profit u/s 115JB of the Act by the amount of reversal of the provision of Rs

Bench: Sh. I. C.Sudhir Judicialmember & Sh. Prashant Maharishia.Y.: - 2008-09 Ranbaxy Laboratories Ltd. Vs Acit 12Th Floor, Devika Tower, Range -15 6, Nehru Place New Delhi New Delhi Pan No. Aaacr0127N (Appellant) (Respondent)

Section (2) to Section 14A of the Act and sub Rule (1) to Rule 8D of the Rules. 14. The view and legal ratio expressed above is not being elucidated for the first time. The Delhi High Court in Maxopp Investment Ltd. v. CIT [2012] 347 ITR 272/203 Taxman 364/15 taxmann.com 390 has observed:- 'Scope of sub-sections

AMADEUS INDIA PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, ITA NO. 7691/Del/2017 stands allowed

Bench: Shri N.S. Saini & Shri Sudhanshu Srivastava

price. Section 92B defines 'international transaction' as under: '92B. Meaning of international transaction.—(1) For the purposes of this section and sections 92, 92C, 92D and 92E, "international transaction" means a transaction between two or more associated enterprises, either or both of whom are non-residents, in the nature of purchase, sale or lease of 24 Stay No. 475, 476/d/2018

AMADEUS INDIA PVT. LTD.,NEW DELHI vs. ACIT, CIRCLE- 2(2), NEW DELHI

In the result, ITA NO. 7691/Del/2017 stands allowed

Bench: Shri N.S. Saini & Shri Sudhanshu Srivastava

price. Section 92B defines 'international transaction' as under: '92B. Meaning of international transaction.—(1) For the purposes of this section and sections 92, 92C, 92D and 92E, "international transaction" means a transaction between two or more associated enterprises, either or both of whom are non-residents, in the nature of purchase, sale or lease of 24 Stay No. 475, 476/d/2018

AMADEUS INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, ITA NO. 7691/Del/2017 stands allowed

Bench: Shri N.S. Saini & Shri Sudhanshu Srivastava

price. Section 92B defines 'international transaction' as under: '92B. Meaning of international transaction.—(1) For the purposes of this section and sections 92, 92C, 92D and 92E, "international transaction" means a transaction between two or more associated enterprises, either or both of whom are non-residents, in the nature of purchase, sale or lease of 24 Stay No. 475, 476/d/2018

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

The appeals are allowed in the above terms, but with no orders as to costs

Transfer Pricing Officer by applying the parameters specified in paragraph17.4 of the order dated 23.01.2013 passed by the Special Bench in the case of LG Electronics India (P) Ltd. v. ACIT? 32. However, on the next date i.e. 30th October 2014, the Court was of the view that the said appeal should be de-linked and passed the following order

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

The appeals are allowed in the above terms, but with no orders as to costs

Transfer Pricing Officer by applying the parameters specified in paragraph17.4 of the order dated 23.01.2013 passed by the Special Bench in the case of LG Electronics India (P) Ltd. v. ACIT? 32. However, on the next date i.e. 30th October 2014, the Court was of the view that the said appeal should be de-linked and passed the following order

JINDAL STAINLESS LTD.,HISAR vs. DCIT, NEW DELHI

Accordingly, ground number 2 of the appeal of the learned AO for 2007 – 08 is dismissed

Bench: Smt Diva Singh & Shri Prashant Maharishi

Transfer Pricing Officer noted that assessee has given a bank guarantee of ₹ 10827.5 lakhs on behalf of its associated enterprise and it has charged ₹ 149.21 lakhs for providing the corporate guarantee to its associated enterprise. The assessee benchmarks the above transaction applying the CUP method. The learned TPO for verification of the applicable rate sought information under section

DCIT, NEW DELHI vs. M/S JSL LTD.,, HISAR

Accordingly, ground number 2 of the appeal of the learned AO for 2007 – 08 is dismissed

Bench: Smt Diva Singh & Shri Prashant Maharishi

Transfer Pricing Officer noted that assessee has given a bank guarantee of ₹ 10827.5 lakhs on behalf of its associated enterprise and it has charged ₹ 149.21 lakhs for providing the corporate guarantee to its associated enterprise. The assessee benchmarks the above transaction applying the CUP method. The learned TPO for verification of the applicable rate sought information under section

AMADEUS INDIA PVT. LTD.,NEW DELHI vs. ACIT, CIRCLE- 2(2), NEW DELHI

In the result, appeal of the assessee in ITA No

Bench: Shri N.K. Billaiya & Ms. Suchitra Kamble[A.Y 2014-15]

price. Section 92B defines 'international transaction' as under: '92B. Meaning of international transaction.—(1) For the purposes of this section and sections 92, 92C, 92D and 92E, "international transaction" means a transaction between two or more associated enterprises, either or both of whom are non-residents, in the nature of purchase, sale or lease of tangible or intangible property

HUMBOLDT WEDAG INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result ITA 3207/Del/2016 stands allowed

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

Transfer Pricing) - 2(1)(1), New Delhi ('Ld. TPO') - under reference from the Ld. AO] erred in making an adjustment of Rs. 14,271,725 to the total income of the Appellant on account of the difference in the arm's length price ('ALP') of its international related party transactions under the provisions of section 92CA(4) of the Income

ACIT, NEW DELHI vs. M/S. HUMBOLDT WEDAG INDIA PVT. LTD., NEW DELHI

In the result ITA 3207/Del/2016 stands allowed

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

Transfer Pricing) - 2(1)(1), New Delhi ('Ld. TPO') - under reference from the Ld. AO] erred in making an adjustment of Rs. 14,271,725 to the total income of the Appellant on account of the difference in the arm's length price ('ALP') of its international related party transactions under the provisions of section 92CA(4) of the Income

HUMBOLDT WEDAG INDIA PVT. LTD.,DELHI vs. ACIT, NEW DELHI

In the result ITA 3207/Del/2016 stands allowed

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

Transfer Pricing) - 2(1)(1), New Delhi ('Ld. TPO') - under reference from the Ld. AO] erred in making an adjustment of Rs. 14,271,725 to the total income of the Appellant on account of the difference in the arm's length price ('ALP') of its international related party transactions under the provisions of section 92CA(4) of the Income

GOODYEAR INDIA LTD.,,FARIDABAD vs. ACIT, NEW DELHI

Bench: : Shri I.C. Sudhir & Shri L.P. Sahu

Section 10 (2) (xv) of the Act if it satisfies otherwise the tests laid down by the law." 85. The OECD Transfer Pricing Guidelines, para 7.13 emphasises that there should not be any automatic inference about an AE receiving an entity group service only because it gets an incidental benefit for being part of a larger concern

M/S. SIS LIVE,GURGAON vs. ACIT, NEW DELHI

In the result the ground No

Bench: I.C.Sudhir & Shri Prashant Maharishisis Live Acit, C/O. Srbc & Associates Llp, Central Circle-17, Room No. Vs. Golf View Corporate Tower B, 356, E-2, Sector-42, Sector Road, Gurgaon Pan:Abrfs4787L (Appellant) (Respondent)

transfer pricing issues in assessment completed u/s 144C read with Section 143(3) of the Act dated 06.02.2015, however, the ld AO vide order u/s 154

AMADEUS INDIA PVT. LTD.,NEW DELHI vs. ACIT, CIRCLE 2(2), NEW DELHI

In the result, the appeal of assessee are allowed

Bench: Sh. Anil Chaturvedi & Sh. Amit Shukla(Through Video Conferencing) Amadeus India Pvt. Ltd., Vs. Acit E-9, Connaught Hose, Circle – 2(2), Connaught Place, New Delhi New Delhi - 110001 Pan No. Aaaca 0364 L (Appellant) (Respondent) Assessee By Shri Taran Deep Singh, Adv. Revenue By Shri Surender Pal, Cit-D.R. Date Of Hearing: 18/05/2021 Date Of Pronouncement: 31/05/2021 Order Per Anil Chaturvedi, Am: This Appeal Filed By The Assessee Is Directed Against The Order Dated 19.09.2019 Of The Asst. Commissioner Of Income Tax, Circle-2(2), Delhi Under Section 143(3) R.W.S 144C(13) Of The Act Pursuant To The Direction Of Dispute Resolution Panel (Drp) – 1, Delhi For Assessment Year 2015-16. 2. The Relevant Facts As Culled From The Material On Records Are As Under :

price. Section 92B defines 'international transaction' as under: '92B. Meaning of international transaction.—(1) For the purposes of this section and sections 92, 92C, 92D and 92E, "international transaction" means a transaction between two or more associated enterprises, either or both of whom are non-residents, in the nature of purchase, sale or lease of tangible or intangible property

BT E- SERV (INDIA) PVT. LTD.,NEW DELHI vs. ITO, NEW DELHI

In the result appeal No. 99/Del/2016 filed by the assessee for assessment year 2011 – 12 is partly allowed

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi & Bt E-Serv (India) Pvt. Ltd, Ito, 11Th Floor, Eros Corporate Tower, Ward-5(2), Vs. Nehru Place, New Delhi New Delhi Pan:Aadcb2533M (Appellant) (Respondent)

Transfer Pricing Officer on outstanding receivable beyond 30 days credit period applying the interest rate of 14.88% p.a. and computing the interest receivable at Rs. 31577050/-. In the result, grounds Nos. 10 to 12 of the grounds of the appeal are dismissed. 23. Ground No. 13 of the appeal of the assessee is with respect to miscalculation of the total