DR. BHIM RAO AMBEDKAR MAHASANG HARYANA,FARIDABAD vs. CIT (EXEMPTIONS), CHANDIGARH/FARIDABAD

In the result, both the appeals are partly allowed for statistical purposes

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarita No. 3195/Del/2017 Assessment Year: 2003-04 Ita No. 3196/Del/2017 Assessment Year: 2004-05 Geodis Overseas Pvt.Ltd., Vs. Asstt. Commissioner Of Building No.5,Tower B, Income Tax, 10Th Floor, Dlf Cyber City, Company Circle- Ii(1), Phase Iii, Gurgaon Chennai-34 Pin: 122 002 Pan No. Aaacc6168L (Appellant) (Respondent)

section 92C (2) of the Act. 11. That on facts and circumstances of the case and in law, the CIT(A) have erred in not directing the AO/TPO to use multiple years data for comparable companies as advocated by the provisions of Rule 10B(4) of the Rules for the purposes of determination of arm's length price. CORPORATE

M/S GEODIS OVERSEAS PVT. LTD.,,GURGAON vs. DCIT,, NEW DELHI

In the result, both the appeals are partly allowed for statistical purposes

section 92C (2) of the Act.\n11. That on facts and circumstances of the case and in law, the CIT(A)\nhave erred in not directing the AO/TPO to use multiple years data for\ncomparable companies as advocated by the provisions of Rule 10B(4) of\nthe Rules for the purposes of determination of arm's length price.\nCORPORATE

DCM SHRIRAM LIMITED,DELHI vs. ASSESSMENT UNIT, DELHI

172/- and paid MAT on book profits. The return of\nincome was revised on 13.07.2016 at an income of INR\n22,56,33,190/-. The case of the assessee was taken up for scrutiny\nand a reference under section 92CA of the Act was made to the TPO\nfor determination of ALP in respect of international transactions\nand specified domestic

DCM SHRIRAM LTD,NEW DELHI vs. ACIT, CIRCLE-7(1), NEW DELHI

172/- and paid MAT on book profits. The return of\nincome was revised on 13.07.2016 at an income of INR\n22,56,33,190/-. The case of the assessee was taken up for scrutiny\nand a reference under section 92CA of the Act was made to the TPO\nfor determination of ALP in respect of international transactions\nand specified domestic

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

172/- and paid MAT on book profits. The return of\nincome was revised on 13.07.2016 at an income of INR\n22,56,33,190/-. The case of the assessee was taken up for scrutiny\nand a reference under section 92CA of the Act was made to the TPO\nfor determination of ALP in respect of international transactions\nand specified domestic

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

172/- and paid MAT on book profits. The return of\nincome was revised on 13.07.2016 at an income of INR\n22,56,33,190/-. The case of the assessee was taken up for scrutiny\nand a reference under section 92CA of the Act was made to the TPO\nfor determination of ALP in respect of international transactions\nand specified domestic

HEWITT ASSOCIATES (INDIA) PVT. LTD.,GURGAON vs. ACIT, NEW DELHI

In the result, the appeal of the assesee is treated as allowed for statistical purposes

Bench: Shri R.K. Panda & Ms. Astha Chandraasstt. Year : 2007-08

172,385 Arm’s length margin 30.07& ALP 1,613,092,221 Price charged by Appellant 1,391,931,625 Difference/ adjustment 22,11,60,596 5. The Ld. AO in his final assessment order dated 31.10.2011 enhanced the income of the assessee by making addition of Rs. 41,20,14,305/- proposed

TELETUBE ELECTRONICS LTD

The appeal of the Assessee is allowed

172 ITR 311(SC) and held that the transaction of lease would fall within the general meaning of transfer of a capital asset. Therefore, it would be futile to examine whether Section 269UA was applicable. The ITAT held that the Explanation to Section 2(47) could be invoked only

TELETUBE ELECTRONICS LTD

The appeal of the Assessee is allowed

172 ITR 311(SC) and held that the transaction of lease would fall within the general meaning of transfer of a capital asset. Therefore, it would be futile to examine whether Section 269UA was applicable. The ITAT held that the Explanation to Section 2(47) could be invoked only

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

DENSO HARYANA PVT. LTD.,NEW DELHI vs. DCIT, CIRCLE- 10(1), NEW DELHI

In the result, appeal is allowed

Bench: Shri Saktijit Dey, Vice- & Dr. Brr Kumarassessment Year: 2010-11 Denso Haryana Pvt. Ltd., Versus Dcit, Circle 10(1), B-1/D-4, Ground Floor, Mohan New Delhi. Cooperative Industrial Estate, Mathura Road, Badarpur, New Delhi. Pan:Aaacd6817F (Appellant) (Respondent) Assessee By : Sh. Himanshu S. Sinha, Adv. Sh. Bhuwan Dhoopar, Adv. Revenue By : Sh. Rajesh Kumar, Cit-Dr Date Of Hearing : 04.09.2023 Date Of Pronouncement: 17.11.2023

Transfer Pricing Officer (TPO) has further stated that the assessee is a routine manufacturer of automobile components and uses all the valuable intellectual property rights, know-how, copyrights and other commercial or marketing intangibles such as brand names, trademarks etc. owned by the DENSO group. 5. In the year under consideration, the assessee entered into various international transactions with

SHAHI EXPORTS PRIVATE LIMITED,NEW DELHI vs. ASSISSTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 8, DELHI, DELHI

In the result, appeal of the assessee is partly allowed

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2021-22] Shahi Exports Pvt.Ltd., Vs Acit, F-88, Okhla Industrial Area, Central Circle-8, Phase-I, New Delhi-110020. Delhi Pan-Aajcs1175L Appellant Respondent Appellant By Shri Shivam Malik, Adv. Respondent By Shri S.K.Jhadav, Cit Dr Date Of Hearing 01.04.2025 Date Of Pronouncement 27.06.2025 Order

transfer of electricity by power producers to third party customers cannot be treated as arm's length price as it is a price under controlled conditions." 17. In the appellant's own case for Assessment Year 2016-17, the coordinate bench of Tribunal vide ITA No. 843/ Del/2021 accepted the appellant's contention and directed the Assessing Officer

PCL FOODS PVT. LTD.,GURGAON vs. ADDI CIT, NATIONAL E- ASSESMENT CENTRE, NEW DELHI

In the result, this appeal of the assessee is partly allowed

Bench: Ms. Madhumita Roy & Shri Brajesh Kumar Singh[Assessment Year: 2016-17] Pcl Foods Private Limited, Additional / Joint/ Unit No.-219, Plot No. 2, Deputy/Assistant Vardhman Crown Mall, Lsc, Vs Commissioner Of Income Sector 19, Dwarka, New Tax/ Income Tax Officer, Delhi-110075. National E-Assessment Centre, Delhi. Pan- Aahcp3493L Assessee Revenue

172/-on account of non-transfer pricing issues. 2. That the final assessment order u/s 143(3) r.w.s. 144C(13)/92CA(3) dt. 22.02.2021 is bad in law. The additions/disallowances made in the order are on wholly illegal, untenable and on erroneous grounds.” ITA No.- 442/Del/2021 PCL Foods Pvt. Ltd. 7.2 The above grounds of appeal are general in nature

MILAN SAINI,GURGAON vs. DCIT, CIRCLE- 2 , GURGAON

In the result, the appeal of the assessee is allowed

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2014-15 Milan Saini, Vs. Dcit, 37, Centrum Plaza, Dlf Golf Circle-2. Course Road, Sector 53, Gurgaon Gurgaon (Haryana) Pan: Braps1366P (Appellant) (Respondent)

172 ITD 425 (Mumbai) 12 (j) Satyam Food Specialties (P.) Ltd. v. Dy. CIT [2015] 68 SOT 449 (Jaipur - Trib.) (k) Ishvakoo Grand Plaza v. DCIT: ITA No. 4537/Del/2017 (Del. Trib) (l) Ms. Padma Rao vs. CIT: [2024] 159 taxmann.com 30 (Del Trib.) 6.9 Compensation received for sterilization of source of income-capital receipt The settlement agreement entered into between

SAC FINANCE COMANY LTD,HONG KONG vs. ACIT, CIRCLE INTERNATIONAL TAXATION 3(1)(2), NEW DELHI

In the result appeal of the assessee in ITA no

Bench: Shri Shamim Yahya & Shri Kul Bharatassessment Year: 2017-18

Transfer Pricing Officer (TPO). TPO accepted the transaction value and passed the order without making any negative inference with respect to arm's length character of transactions (refer para 3.1 to para 5 at page 138 of paper book) 7. Thereafter, in the final order after DRP directions the Ld.AO made the following adjustment to the sale value of shares

APTIV COMPONENTS INDIA P.LTD (FORMERLY KNOWN AS DELPHI AUTOMOTIVE SYSTEMS P.LTD),NEW DELHI vs. ACIT, CIRCLE-1(1), NEW DELHI

In the result, the appeal of the assessee is partly allowed

Bench: Shri M. Balaganesh & Shri Anubhav Sharmam/S Aptive Components India Vs. Acit, Private Limited (Formerly Known Circle-1(1), As M/S Delphi Automotive New Delhi System Private Limited), P-24, Green Park Extension, New Delhi (Appellant) (Respondent) Pan: Aaacd0226F Assessee By : Shri Ajay Vohra, Sr. Adv Shri Neeraj Jain, Adv Ms. Richa Aggarwal, Adv Revenue By: Shri Amit Kumar Singh, Sr. Dr Date Of Hearing 04/07/2025 Date Of Pronouncement 01/10/2025

section 92CA(3) dated 30.07.2021 for AY 2018-19. M/s Aptive Components India Private Limited 2. The Ground No. 1 is general in nature and does not require any specific adjudication. 3. The Ground No. 2 raised by the assessee was stated to be not pressed by the Learned AR at the time of hearing. The Learned AR has also