DCM SHRIRAM LIMITED,DELHI vs. ASSESSMENT UNIT, DELHI

transfer of steam has taken though additional grounds\nITA Nos.927 & 2587/Del/2022,\n704/Del/2021, 4328 & 1495/Del/2024\nPage | 42 \nof appeal be admitted and additional evidences filed in support of\nthe additional claim may deserves to be admitted in the interest of\njustice.\n44. On the other hand, Ld. CIT DR seriously objected the\nadmission of additional grounds as well as admission

DCM SHRIIRAM LIMITED,NEW DELHI vs. NEAC, NEW DELHI

transfer of steam has taken though additional grounds\n\nPage | 42\n\nof appeal be admitted and additional evidences filed in support of\nthe additional claim may deserves to be admitted in the interest of\njustice.\n\n44. On the other hand, Ld. CIT DR seriously objected the\nadmission of additional grounds as well as admission of additional\nevidences

DCIT, NEW DELHI vs. DCM SHRIRAM LTD, NEW DELHI

transfer of steam has taken though additional grounds\n\nPage | 42\n\nITA Nos.927 & 2587/Del/2022,\n704/Del/2021, 4328 & 1495/Del/2024\n\nof appeal be admitted and additional evidences filed in support of\nthe additional claim may deserves to be admitted in the interest of\njustice.\n\n44. On the other hand, Ld. CIT DR seriously objected the\nadmission of additional grounds

SRF LIMITED ,DELHI vs. ACIT, CIRCLE-10(1), DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

prices at which power was purchased from respective State Electricity Board. 64. In a case where the assessee operates a Wind Power Mill (WPP) unit at Tamil Nadu to generate electricity primarily for consumption by its manufacturing units. During the year, the assessee had transferred the WPP units at effective rate of Rs. 6.35 p.u, based on fact that Tamil

SRF LIMITED,NEW DELHI vs. ACIT, CIRCLE-10(1), DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

prices at which power was purchased from respective State Electricity Board. 64. In a case where the assessee operates a Wind Power Mill (WPP) unit at Tamil Nadu to generate electricity primarily for consumption by its manufacturing units. During the year, the assessee had transferred the WPP units at effective rate of Rs. 6.35 p.u, based on fact that Tamil

SRF LIMITED,DELHI vs. ASSISTANT / DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 10(1), NEW DELHI, DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

prices at which power was purchased from respective State Electricity Board. 64. In a case where the assessee operates a Wind Power Mill (WPP) unit at Tamil Nadu to generate electricity primarily for consumption by its manufacturing units. During the year, the assessee had transferred the WPP units at effective rate of Rs. 6.35 p.u, based on fact that Tamil

MARUBENI INDIA PVT. LTD

In the result the appeal of the revenue in ITA No

155 Admn. & Other 119,967,293 Depreciation 9,830,666 Total Cost (A) 212,994,114 Cost Plus markup of 8.37% (A) 230,821,721 Amount earned as commission and service fees (B) 204,771,840 Amount short charged (A-B) 26,049,881 The arm’s length price in respect of commission and market research service. fees is therefore

GLOBAL LOGIC INDIA LIMITED,DELHI vs. DCIT TPO-2(1)(1), DELHI

In the result the appeal of the assessee is allowed

Bench: Shri Shamim Yahya & Ms. Astha Chandraassessment Year: 2017-18

155 Inc. received from AE B. Deemed International Transactions Associated Deemed International Transfer Price Enterprise Transaction (in Rs.) Oracle India Provision of software 17,12,280 Pvt. Ltd. development services 5. In its transfer pricing report for the financial year ended 31.03.2017, the assessee has reported that in respect of international transactions pertaining to provision of software development services

SONY INDIA PRIVATE LIMITED,NEW DELHI vs. ACIT, CIRCLE-22(2), DELHI

The appeals are allowed partly with consequence to\nfollow as per the determination of grounds as above

15% and for\nbenchmarking the said transaction the assessee chose TNMM as the most\nappropriate method. The average margin of comparables was calculated in a\n\nrange of 16.37% and 20.24% and, thus, the transaction was claimed to be at\narm's length.\n\n14. In assessee's own case for AY 2016-17 (supra), the issue was restored

SONY INDIA PRIVATE LIMITED,NEW DELHI vs. ACIT, CIRCLE-22(2), DELHI

The appeals are allowed partly with consequence to\nfollow as per the determination of grounds as above

15% and for\nbenchmarking the said transaction the assessee chose TNMM as the most\nappropriate method. The average margin of comparables was calculated in a\nrange of 16.37% and 20.24% and, thus, the transaction was claimed to be at\narm's length.\n\n14. In assessee's own case for AY 2016-17 (supra), the issue was restored to\nthe

SONY INDIA PVT. LTD.,NEW DELHI vs. ACIT CIRCLE-24(1), NEW DELHI

The appeals are allowed partly with consequence to\nfollow as per the determination of grounds as above

15% and for\nbenchmarking the said transaction the assessee chose TNMM as the most\nappropriate method. The average margin of comparables was calculated in a\nrange of 16.37% and 20.24% and, thus, the transaction was claimed to be at\narm's length.\n\n14. In assessee's own case for AY 2016-17 (supra), the issue was restored to\nthe

GEOPETROL INTERNATIONAL INC.,CHENNAI vs. ACIT, CIRCLE INTERNATIONAL TAXATION1(3)1,, NEW DELHI

In the result, appeal of the assessee is partly allowed for statistical purpose

Bench: SHRI VIKAS AWASTHY (Judicial Member), SHRI BRAJESH KUMAR SINGH (Accountant Member)

Transfer Pricing Officer (TPO) u/s. 92CA(3) of the Act wherein variation has been made by him, and(ii) the assessee must be a foreign company. Both the conditions as specified in sub clause (i) and (ii) of clause (b)should be satisfied to fall within the meaning of ‘eligible assessee’. In the instant case there is no order

SCHNEIDER ELECTRIC INDIA PVT. LTD.,GURGAON vs. ACIT, NEW DELHI

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Vikas Awasthy & Shri Pradip Kumar Kedia[Assessment Year : 2007-08] Schneider Electric India Vs Acit Pvt.Ltd., 9Th Floor, Tower C Circle-22(2) Building No.10, Dlf Cyber Room No. 226 City, Phase-Ii, Gurgaon C.R. Building Hartyana-122002 New Delhi-110002 Pan-Aabcs1642G Appellant Respondent Appellant By Shri Rohit Tiwari, Adv. & Tanya, Adv. Respondent By Shri Rajesh Kumar Dhanesta, Sr.Dr Date Of Hearing 17.01.2025 Date Of Pronouncement 09.04.2025

transfer pricing adjustment to the file of the AO/TPO for fresh adjudication. During the remand back proceedings, various submissions were filed before the TPO containing the contentions with respect to both service segments. A Summary of the submissions filed has been provided below for the Bench's ready reference: S.No. Date of submission Particulars 1. October 07, 2014 Application

HERO MOTOCORP LTD (AS SUCCESSOR OF HERO INVESTMENT P.LTD),NEW DELHI vs. DCIT, CIRCLE 11(1), NEW DELHI

The appeal is allowed

Bench: Shri G.S. Pannu & Shri Anubhav Sharmaassessment Year: 2011-12

15. Thus we concluded that theory of "discounted price" of share transfer, out of concession advanced to Honda, as assumed by the assessing officer, had no substance. The above discussion reinforces our view that the AO while recording the ‘reasons to believe’ has harped upon his own perception about the transaction of purchase of shares by the Hero group

DCIT, CIRCLE- 1(1)(1), INTERNATIONAL TAXATION, NEW DELHI vs. A.T. KEARNEY LTD., GURGAON

In the result, appeals of the Assessee’s in ITA Nos

Bench: SHRI SHAMIM YAHYA (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Transfer Pricing Regulations. AT Kearney Limited vs. DCIT 4.6 The assessee submitted that a detailed analysis was conducted by the assessee to determine the functions performed, risks assumed and assets utilized by the Appellant and its AEs with respect to various international transactions undertaken during the subject year under appeal in the TP documentation. Further, as per the assessee

AT KEARNEY LTD.- INDIA BRANCH OFFICE,GURGAON vs. DCIT, CIRCLE- 1(1)(1), INTERNATIONAL TAXATION, NEW DELHI

In the result, appeals of the Assessee’s in ITA Nos

Bench: SHRI SHAMIM YAHYA (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Transfer Pricing Regulations. AT Kearney Limited vs. DCIT 4.6 The assessee submitted that a detailed analysis was conducted by the assessee to determine the functions performed, risks assumed and assets utilized by the Appellant and its AEs with respect to various international transactions undertaken during the subject year under appeal in the TP documentation. Further, as per the assessee

AT KEARNEY LTD.- INDIA BRANCH OFFICE,GURGAON vs. DCIT, CIRCLE- 1(1)(1), INTERNATIONAL TAXATION, NEW DELHI

In the result, appeals of the Assessee’s in ITA Nos

Bench: SHRI SHAMIM YAHYA (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Transfer Pricing Regulations. AT Kearney Limited vs. DCIT 4.6 The assessee submitted that a detailed analysis was conducted by the assessee to determine the functions performed, risks assumed and assets utilized by the Appellant and its AEs with respect to various international transactions undertaken during the subject year under appeal in the TP documentation. Further, as per the assessee

DCIT, CIRCLE- 1(1)(1), INTERNATIONAL TAXATION, NEW DELHI vs. A.T. KEARNEY LTD., GURGAON

In the result, appeals of the Assessee’s in ITA Nos

Bench: SHRI SHAMIM YAHYA (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Transfer Pricing Regulations. AT Kearney Limited vs. DCIT 4.6 The assessee submitted that a detailed analysis was conducted by the assessee to determine the functions performed, risks assumed and assets utilized by the Appellant and its AEs with respect to various international transactions undertaken during the subject year under appeal in the TP documentation. Further, as per the assessee