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

BSC C&C JOINT VENTURE,NEW DELHI vs. DCIT, CIRCLE-61(1), NEW DELHI

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

Bench: SHRI G.S. PANNU (Vice President), SHRI ANUBHAV SHARMA (Judicial Member)

172 2. Mokama- Munger NHAI Two laining with 2.43.46,365 paved shoulder of (Through Mokama Munger Project Section of NH-Bo Company Mokama- Munger Highway Ltd. 3. Danapur ROB Ircon Construction of 72,30,449 International Road over Bridge Ltd. both railway span and adjacent approaches including Reinforced Earth Wall/Retaining Wall between section Phulwarishrif- Danapur on EC Railway, Bihar 4

BSC C&C JOINT VENTURE,NEW DELHI vs. DCIT CIRCLE-61(1),, NEW DELHI

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

Bench: Shri M Balaganesh & Ms. Astha Chandraasstt. Year: 2017-18

Transfer Pricing Officer (“TPO”) who vide his order dated 29.01.2021 proposed adjustment of Rs. 1,14,41,802/- on account of interest on advance given to BSC C&C JV Nepal Ltd. The Ld. Assessing Officer, National Faceless Assessment Centre, Delhi (“FAO”) 3 proceeded to frame draft order under section 144C of the Act. He computed the total income

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

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

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

4 at Page 7 of the appeal set), wherein the Officer only\nsubmitted that the additional evidence deserves to be rejected on the\nground that the Appellant had itself applied TNMM for benchmarking the\nfreight forwarding transaction and never contended to apply comparable\nuncontrolled price (\"CUP\") method either in the transfer pricing study or\nduring the assessment proceedings

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

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 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

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

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

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

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. 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

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

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

172,84,07,356 Import of finished goods Import of capital 12,40,40,466 goods Export of finished 4,22,25,268 goods Payment of royalty 10,63,39,944 Payment for technical 1,43,31,239 services Payment of application 4,11,32,802 cost Payment for receipt of services 72,27,543 Payment of training

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

DIRECTOR OF INCOME TAX vs. INFRASOFT LTD

transfer to the copy/copies any copyright or other marking on the Software or Documentation. 2013:DHC:6018 ======================================================================= ITA 1034/2009 Page 100 of 174 (d) Not use the Software or Documentation for any other purpose than permitted in this Article 20, Licence or sell or in any manner alienate or part with its possession. (e) Not use or transfer the Software