ECOENERGY INSIGHTS LTD ( FORMERLY KNOWN AS CHUBB ALBA CONTROL SYSTEMS P.LTD),NEW DELHI vs. DCIT, CIRCLE-4(2), NEW DELHI

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

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaecoenergy Insights Ltd., Vs. Dcit, (Formerly Known As Chubb Alba Control Circle 4 (2), Systems P. Ltd.), New Delhi. Ground Floor, 18, Netaji Subhash Marg, Daryaganj, New Delhi – 110 002. (Pan :Aaaca0031C) (Appellant) (Respondent) Assessee By : Shri Nageshwar Rao, Advocate Shri Parth, Advocate Shri Pratik Rath, Advocate Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 12.08.2025 Date Of Order : 10.11.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Assessment Order Dated 25.07.2022Passed By The Assessment Unit, Income Tax Department Under Section 147 Read With Section 144C(13) R.W.S. 144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Ay 2018-19 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act.

Section 144B(5) of the Act. Thus, the assessment proceedings are vitiated in law and liable to be quashed. Grounds against addition proposed in relation to transfer of specified asset 3. That on the facts and circumstances of the case and in law, the impugned order is bad in law as the adjustment made in relation to transfer of specified

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)

Transfer Pricing Officer passed order under section 92CA(3) on 22-02-2006 wherein he determined an adjustment of Rs.2,23,96,778/- to be made to the value of international transactions entered into by the assessee. Hence, a sum of Rs.2,23,96,778/- is reduced from the loss shown by the assessee. 5. The assessee has claimed

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)

Transfer Pricing Officer passed order under section 92CA(3) on 22-02-2006 wherein he determined an adjustment of Rs.2,23,96,778/- to be made to the value of international transactions entered into by the assessee. Hence, a sum of Rs.2,23,96,778/- is reduced from the loss shown by the assessee. 5. The assessee has claimed

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

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

Transfer Pricing Officer passed\norder under section 92CA(3) on 22-02-2006 wherein he determined an\nadjustment of Rs.2,23,96,778/- to be made to the value of international\ntransactions entered into by the assessee. Hence, a sum of Rs.2,23,96,778/- is\nreduced from the loss shown by the assessee.\n5. The assessee has claimed

DCM SHRIRAM LIMITED,DELHI vs. ASSESSMENT UNIT, DELHI

193, wherein the\nHon'ble SC remarked as \"The legitimate occasion for the application of\nOrder 41, rule 27 is when on examining the evidence as it stands, some\ninherent lacuna or defect becomes apparent, not where a discovery is\nmade, outside the court of fresh evidence and the application is made to\nimpart it. The true test, therefore

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

193, wherein the\nHon'ble SC remarked as \"The legitimate occasion for the application of\nOrder 41, rule 27 is when on examining the evidence as it stands, some\ninherent lacuna or defect becomes apparent, not where a discovery is\nmade, outside the court of fresh evidence and the application is made to\nimpart it. The true test, therefore

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

193, wherein the\nHon'ble SC remarked as \"The legitimate occasion for the application of\nOrder 41, rule 27 is when on examining the evidence as it stands, some\ninherent lacuna or defect becomes apparent, not where a discovery is\nmade, outside the court of fresh evidence and the application is made to\nimpart it. The true test, therefore

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

193, wherein the\nHon'ble SC remarked as \"The legitimate occasion for the application of\nOrder 41, rule 27 is when on examining the evidence as it stands, some\ninherent lacuna or defect becomes apparent, not where a discovery is\nmade, outside the court of fresh evidence and the application is made to\nimpart it. The true test, therefore

PEPSICO INDIA HOLDINGS PVT. LTD.,GURGAON vs. ACIT, CENTRAL CIRCLE-7, NEW DELHI

In the result, the appeal of the assessee is allowed and the Stay

Bench: Shri Shamim Yahya & Ms. Astha Chandra[Assessment Year: 2018-19]

193,40,86,053/-. 6. That the TPO/AO/DRP/NFAC erred in not following the decision of this Hon’ble Tribunal in Appellant’s own case for immediately preceding years, wherein this Hon’ble Tribunal deleted identical Transfer Pricing Adjustment on account of AMP Expenses. M/s PepsiCo India Holdings Pvt. Ltd. 7. That the TPO/AO/DRP/NFAC, despite duly making a note

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 ,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

GATES INDIA PVT LTD,DELHI vs. ACIT, CIRCLE-10(1), DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kedia

193 ITR 321 (SC) to invoke the principles of consistency. (v) The TPO has exceeded his jurisdiction to determine ALP of management charges at ‘Nil’ under CUP method on the basis of no benefit accrued to the assessee. The jurisdiction of the TPO is to conduct Transfer Pricing Analysis to determine ALP by applying one of the five methods prescribed

SONY INDIA PRIVATE LIMITED,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME-TAX, NEW DELHI

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

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Transfer pricing officer issued 2 Show cause notices - At page 462 of paper book 2A, SCN relating to AMP can be found and at page 338 of paper book 2A, SCN issued in connection with Software services can be seen. Kind attention is invited to page 462 paper book 2A-show cause notice refers to "Benchmarking of REIMBUSEMENT OF MARKETING

DCIT, NEW DELHI vs. M/S. SONY INDIA PVT. LTD., NEW DELHI

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

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Transfer pricing officer issued 2 Show cause notices - At page 462 of paper book 2A, SCN relating to AMP can be found and at page 338 of paper book 2A, SCN issued in connection with Software services can be seen. Kind attention is invited to page 462 paper book 2A-show cause notice refers to "Benchmarking of REIMBUSEMENT OF MARKETING

DEV PRIYA PRODUCTS PRIVATE LTD.,DELHI vs. DCIT, CENTRAL CIRCLE, MEERUT

In the result, appeal of the assessee is partly allowed

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2020-21] Dev Priya Products Pvt.Ltd., Vs Dcit/Acit, 4, Shankar Vihar, 1St Floor, Central Circle, Vikas Marg, Delhi-110092. Meerut Pan-Aaacd4276C Appellant Respondent Appellant By Shri Ved Jain, Adv. & Shri Ayush Garg, Ca Respondent By Shri S.K.Jhadav, Cit Dr Date Of Hearing 02.04.2025 Date Of Pronouncement 27.06.2025 Order

section 234A, 234B and 234C of the Act. 12. That the appellant craves leave to add, amend or alter any of the grounds of appeal.” Ground No.1 is general in nature, needs no adjudication. 4. Ground No.2 is not pressed hence, dismissed. 5. Ground Nos.3 & 4 are with respect to the adjustments made 6. to the total income

GOODYEAR INDIA LTD.,FARIDABAD vs. DCIT, CIRCLE-10(1), NEW DELHI

In the result, the appeal of the assessee in ITA No

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

section 144C/143(3) of the Income-tax Act, 1961 (‘the Act’) at an income of Rs. 255,67,96,910 as against the income of Rs. 193,62,59,440 determined by the appellant in its income tax return. 1.2 That the assessing officer erred on facts and in law in making an aggregate addition

GOODYEAR INDIA LTD,FARIDABAD vs. ACIT, CIRCLE-10(1), NEW DELHI

In the result, the appeal of the assessee in ITA No

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

section 144C/143(3) of the Income-tax Act, 1961 (‘the Act’) at an income of Rs. 255,67,96,910 as against the income of Rs. 193,62,59,440 determined by the appellant in its income tax return. 1.2 That the assessing officer erred on facts and in law in making an aggregate addition