M/S. HONDA SIEL POWER PRODUCTS LTD.,GAUTAM BUDH NAGAR vs. DCIT, NEW DELHI

In the result, both the appeals of the assessee-company are partly allowed for statistical purposes

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

section 40(a)(i) are directed to be deleted. Accordingly, these grounds of appeal stand allowed. In view of this decision of co-ordinate Bench in the case of assessee, the advance ruling relied on by the ld. DR does not help the revenue, as the said ruling is binding on that applicant and not upon the Tribunal u/s. 245S

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

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)

190/-. The case was taken up for scrutiny. In response to notices under Sections 143(2) and 142(1) of the Act, Shri D.C.Gupta, Sr. Manager (Finance & Accounts) of the company appeared and filed details. 4. The assessee had international transactions exceeding Rs.5 crores with its associated enterprises. Hence the case was referred to the Transfer Pricing

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)

190/-. The case was taken up for scrutiny. In response to notices under Sections 143(2) and 142(1) of the Act, Shri D.C.Gupta, Sr. Manager (Finance & Accounts) of the company appeared and filed details. 4. The assessee had international transactions exceeding Rs.5 crores with its associated enterprises. Hence the case was referred to the Transfer Pricing

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

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

190/-. The case was taken up for\nscrutiny. In response to notices under Sections 143(2) and 142(1) of the Act,\nShri D.C.Gupta, Sr. Manager (Finance & Accounts) of the company appeared\nand filed details.\n4. The assessee had international transactions exceeding Rs.5 crores with its\nassociated enterprises. Hence the case was referred to the Transfer Pricing

ANALJIT SINGH,DELHI vs. DCIT, CIRCLE- 16(2), DELHI

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

Bench: Shri Amit Shukla & Shri O.P.Kant

transfer price” of Rs. 1241.32 crores, which was a mutually negotiated and agreed consideration. Clause 3.2 of the said Agreement provided that the parties would request Kotak, a SEBI registered Category I merchant banker, to prepare a valuation report relating to the fair market value of VIL pursuant to Schedule 1 of the Framework Agreement dated 5.7.2007, to confirm

DCM SHRIRAM LIMITED,DELHI vs. ASSESSMENT UNIT, DELHI

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 transactions carried out by the assessee\nduring the previous year relevant to year under appeal. The\nassessee has carried out following international

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

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 transactions carried out by the assessee\nduring the previous year relevant to year under appeal. The\nassessee has carried out following international

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

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 transactions carried out by the assessee\nduring the previous year relevant to year under appeal. The\nassessee has carried out following international

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

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 transactions carried out by the assessee\nduring the previous year relevant to year under appeal. The\nassessee has carried out following international

ACIT (LTU), NEW DELHI vs. MAX NEW YORK LIFE INSURANCE COMPANY LTD., NEW DELHI

In the result, the appeal is allowed for statistical purposes

Bench: Shri R.S. Syal & Shri Sudhanshu Srivastavaassessment Year : 2002-03

section 92 of the Act, by making addition on account of transfer pricing adjustment, if warranted. The additional ground raised under Rule 27 of the ITAT Rules, 1963, is, therefore, dismissed. 21. Now we take up the issue on merits. It is essential to mention that Sh. M.S. Syali, the ld. Sr Advocate argued the additional ground raised under rule

PEPSICO INDIA HOLDINGS PVT. LTD.,GURGAON vs. ACIT, CC-07, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri G. S. Pannua N D Shri Challa Nagendra Prasad

section 92B of the Act based on assumptions, surmises and conjectures. 12. Without prejudice, the TPO/DRP/AO erred in concluding that the AMP expenses incurred by the Appellant resulted in the enhanced brand value of the brands owned by the AE. 13. Without prejudice, the TPO/DRP/AO erred in concluding that the AE reaped the benefits of marketing activities carried

SAMSUNG INDIA ELECTRONICS PVT. LTD.,GURGAON vs. DCIT CIRCLE-22(2), NEW DELHI

In the result, the appeal of the assessee is partly allowed in the aforesaid manner

Bench: Shri G. S. Pannu & Shri Yogesh Kumar U.S.

section 144C. On merits, he submitted that TNMM is not an appropriate method to judge the arm’s length price of royalty as the same is not inextricably linked with other transactions. The payment of royalty is not under a “package deal” comprising of numerous transactions. Each transaction is separate and diverse. Therefore, transfer pricing norms require separate benchmarking

DDIT, DEHRADUN vs. BG EXPLORATION & PRODUCTION INDIA LTD., MUMBAI

In the result ground No. 2 of the appeal of the assessee is dismissed

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

Section 144C(5) . The DRP procedure can only be initiated by an assessee objecting to the draft assessment order. This would enable correction in the proposed order (draft assessment order) before a final assessment order is passed. Therefore, we are of the view that in the present facts this issue could be agitated before and rectified

DCIT, NEW DELHI vs. M/S GLOBAL GREEN COMPANY LTD.,, NEW DELHI

In the result, the appeals of the assessee are partly allowed for statistical purpose and the appeals of the revenue are dismissed

Bench: Sh. C. N. Prasaddr. B. R. R. Kumar

transfer pricing addition of Rs. 7,90,535/- made by the AO/TPO in respect of transaction of purchase of packing materials from an associated enterprise. 4.2 The Appellant humbly prays that since the purchase price at which the Appellant has entered into the international transaction of purchase of packing material is less than the ALP determined

DCIT, CIRCLE- 10(1), NEW DELHI vs. GLOBAL GREEN COMPANY LTD., NEW DELHI

In the result, the appeals of the assessee are partly allowed for statistical purpose and the appeals of the revenue are dismissed

Bench: Sh. C. N. Prasaddr. B. R. R. Kumar

transfer pricing addition of Rs. 7,90,535/- made by the AO/TPO in respect of transaction of purchase of packing materials from an associated enterprise. 4.2 The Appellant humbly prays that since the purchase price at which the Appellant has entered into the international transaction of purchase of packing material is less than the ALP determined

GLOBAL GREEN COMPANY LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeals of the assessee are partly allowed for statistical purpose and the appeals of the revenue are dismissed

Bench: Sh. C. N. Prasaddr. B. R. R. Kumar

transfer pricing addition of Rs. 7,90,535/- made by the AO/TPO in respect of transaction of purchase of packing materials from an associated enterprise. 4.2 The Appellant humbly prays that since the purchase price at which the Appellant has entered into the international transaction of purchase of packing material is less than the ALP determined

GLOBAL GREEN COMPANY LTD.,NEW DELHI vs. DCIT, CIRCLE- 10(1), NEW DELHI

In the result, the appeals of the assessee are partly allowed for statistical purpose and the appeals of the revenue are dismissed

Bench: Sh. C. N. Prasaddr. B. R. R. Kumar

transfer pricing addition of Rs. 7,90,535/- made by the AO/TPO in respect of transaction of purchase of packing materials from an associated enterprise. 4.2 The Appellant humbly prays that since the purchase price at which the Appellant has entered into the international transaction of purchase of packing material is less than the ALP determined

GLOBAL GREEN COMPANY LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeals of the assessee are partly allowed for statistical purpose and the appeals of the revenue are dismissed

Bench: Sh. C. N. Prasaddr. B. R. R. Kumar

transfer pricing addition of Rs. 7,90,535/- made by the AO/TPO in respect of transaction of purchase of packing materials from an associated enterprise. 4.2 The Appellant humbly prays that since the purchase price at which the Appellant has entered into the international transaction of purchase of packing material is less than the ALP determined