M/S LG ELECTRONICS INDIA PVT. LTD.,,NEW DELHI vs. DCIT, NOIDA

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

DCIT, NOIDA vs. M/S. L.G. ELECTRONICS INDIA PVT. LTD., GREATER NOIDA

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

LG ELECTRONICS INDIA PRIVATE LIMITED,MATHURA ROAD, NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

LG ELECTRONICS INDIA PRIVATE LIMITED ,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

LG ELECTRONICS INDIA PVT. LTD.,NEW DELHI vs. DCIT, CIRCLE-15(2), NEW DELHI

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

LG ELECTRONICS INDIA PVT. LTD.,NEW DELHI vs. ADDL. CIT, SPECIAL RANGE- 5, NEW DELHI

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

LG ELECTRONICS INDIA PVT. LTD.,NEW DELHI vs. ADDL. CIT, SPECIAL RANGE- 5, NEW DELHI

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

DCIT, CIRCLE-15(2), NEW DELHI vs. LG ELECTRONICS INDIA PVT. LTD., NEW DELHI

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

DCIT, CIRCLE-13(1), NEW DELHI vs. LG ELECTRONICS INDIA PVT. LTD., DELHI

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

TUPPERWARE INDIA PVT. LTD.,NEW DELHI vs. ADDL. CIT, SPECIAL RANGE- 9, NEW DELHI

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

Bench: Shri R.K. Panda & Ms. Astha Chandraassessment Year: 2013-14

section 195 of the Act. 22.1.6 The Ld. AR also submitted that since the Ld. TPO examined the transaction of reimbursement of expenses in detail during the transfer pricing

ACIT, CIRCLE-8(1), NEW DELHI vs. EFS FACILITIES SERVICES (INDIA) PVT. LTD., NEW DELHI

In the result, both the appeals of the Revenue for assessment year

Bench: Dr. B.R.R. Kumar & Ms. Astha Chandra

Transfer Pricing Officer (“TPO”) under section 92CA of the Income Tax Act 1961 (“Act”) for ascertaining arm’s length price (“ALP”) of the above transactions. The Ld. TPO vide order dated 18.10.2016 has proposed to make the following adjustments :- S. No. Type of International Transaction Total Value of Transaction (Rs.) 1. Intra Group Service - Employee 34,11,787 Secondment

ACIT, CIRCLE-8(1), NEW DELHI vs. EFS FACILITIES SERVICES (INDIA) PVT. LTD., NEW DELHI

In the result, both the appeals of the Revenue for assessment year

Bench: Dr. B.R.R. Kumar & Ms. Astha Chandra

Transfer Pricing Officer (“TPO”) under section 92CA of the Income Tax Act 1961 (“Act”) for ascertaining arm’s length price (“ALP”) of the above transactions. The Ld. TPO vide order dated 18.10.2016 has proposed to make the following adjustments :- S. No. Type of International Transaction Total Value of Transaction (Rs.) 1. Intra Group Service - Employee 34,11,787 Secondment

TIMEX GROUP INDIA LTD.,NEW DELHI vs. ADDI. CIT SPL.RANGE-9, NEW DELHI

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

Bench: Shri Vimal Kumar & Shri Brajesh Kumar Singh[Assessment Year: 2013-14] M/S Timex Group India Ltd. Additional Commissioner Of Income 106-107, Ambadeep Building, Tax, Special Range-9, Kasturba Gandhi Marg, Vs New Delhi-110002 New Delhi-110001 Pan-Aaact0773C Assessee Revenue [Assessment Year: 2013-14] Additional Commissioner Of M/S Timex Group India Ltd. Income Tax, Special Range-9, 106-107, Ambadeep Building, New Delhi-110002 Vs Kasturba Gandhi Marg, New Delhi-110001 Pan-Aaact0773C Revenue Assessee Assessee By Shri Tushar Jarwal, Adv. Shri Aayush Nagpal, Adv. & Shri Vikrant Maheshwari, Adv. Revenue By Shri Rohit Garg, Cit-Dr Date Of Hearing 01.07.2025 Date Of Pronouncement 26.09.2025

Transfer Pricing Guidelines, OECD BEPS Action Plan 8-10 and other international commentaries, particularly with reference to determination of arm's length price for marketing intangibles. 11. That on the facts and in the circumstances of the case and in law, the Ld. CIT (A) has erred in upholding the action of the AO in disallowing the payments made

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

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

ACIT , SPL. RANGE-9, NEW DELHI vs. TIMEX GROUP INDIA LTD., NEW DELHI

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

Bench: Shri Vimal Kumar\Nand\Nshri Brajesh Kumar Singh\Nita No.7526/Del/2019\N[Assessment Year: 2013-14]\N\Nm/S Timex Group India Ltd.\N106-107, Ambadeep Building,\Nkasturba Gandhi Marg,\Nnew Delhi-110001\Npan-Aaact0773C\Nassessee\Nvs\Nadditional Commissioner Of Income\Ntax, Special Range-9,\Nnew Delhi-110002\Nrevenue\Nita No.7598/Del/2019\N[Assessment Year: 2013-14]\N\Nadditional Commissioner Of\Nincome Tax, Special Range-9,\Nnew Delhi-110002\Nm/S Timex Group India Ltd.\N106-107, Ambadeep Building,\Nvs Kasturba Gandhi Marg,\Nnew Delhi-110001\Npan-Aaact0773C\Nrevenue\Nassessee\Nassessee By\Nshri Tushar Jarwal, Adv.\Nshri Aayush Nagpal, Adv. &\Nshri Vikrant Maheshwari, Adv.\Nrevenue By\Nshri Rohit Garg, Cit-Dr\Ndate Of Hearing\N01.07.2025\Ndate Of Pronouncement\N26.09.2025\Norder\Nper Brajesh Kumar Singh, Am,\Nthese Are Cross Appeals Filed By The Assessee As Well As By\Nthe Revenue, Against The Order Of The Ld. Commissioner Of\Nincome Tax (Appeals)-44, New Delhi, Dated 28.06.2019 Arising\Nfrom The Assessment Order Dated 07.02.2017 Passed Under\Nsection 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred\Nto As 'The Act') Relating To Assessment Year 2013-14.\N1.

sections": [ "143(3)", "40(a)(i)", "92CA", "92B", "92C", "92CC", "195", "40(a)(i)", "9(1)(vii)", "12(4)", "12(5)", "12(6)(d)", "14", "7" ], "issues": "1. Whether AMP expenses could be characterized as international transactions and whether the methodology adopted for transfer pricing

DELPHI AUTOMOTIVE SYSTEMS (P) LTD,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME-TAX, NEW DELHI

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

Bench: Shri M. Balaganesh & Shri Anubhav Sharmaaptive Components India P. Ltd, Vs. Deputy Commissioner (Formerly Known As Delphi Of Income-Tax, Automotive Systems P. Ltd), Circle-7(1), P-24, Green Park Extension, New Delhi South Delhi, New Delhi-110016 (Appellant) (Respondent) Pan:Aaacd0226E

transfer pricing provisions and also considering the fact that both the comparable company as well as its holding company are Indian resident entities, the provisions of section 92B(2) of the Act having deeming fiction cannot be made applicable to the facts of the instant case. With regard to the decision relied upon by the ld AR in the case