(Now known as Sony India Limited)

47. The majority decision of the Tribunal in L.G. Electronics India Pvt Ltd. (supra) has rightly drawn a distinction between sub-section (2B) and sub-section (2A) to Section 92CA of the Act. Sub-section (2A) was inserted in 2011, i.e. nearly one year before insertion of Section (2B) by the Finance Act, 2012. Sub- section (2A) has not been

COMMISSIONER OF INCOME TAX vs. MENTOR GRAPHICS (NOIDA) PVT.LTD

The appeal is allowed

section 92C on the basis of such material or informaction or document available with him. After the Transfer Pricing Officer determines the arm’s length price, it is incumbent upon him to send a copy of the order to the assessing officer and to the assessee. In the present case what has happened is that the Transfer Pricing Officer

ACIT, NEW DELHI vs. M/S. KCT PAPERS LTD., NEW DELHI

In the result, grounds raised by the revenue are dismissed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharmaacit, Circle 5 (1) Vs. M/S. Kct Papers Limited, New Delhi. Thapar House, 124, Janpath, New Delhi – 110 001. (Pan : Aacck4937D) (Appellant) (Respondent) Assessee By : Shri Rohit Jain, Advocate Shri Deepesh Jain, Advocate Shri Tavish Verma, Advocate Revenue By : Shri Kailash Dan Ratnoo, Cit Dr Date Of Hearing : 10.09.2025 Date Of Order : 05.12.2025 O R D E R Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax (Appeals)-Viii, New Delhi [Hereinafter Referred To As ‘Ld. Cit (A)] Dated 21.03.2014For Assessment Year 2008-09. 2. Brief Facts Of The Case Are, The Assessee Company Belongs To The Thapar Group Established By Late Lala Karam Chand Thapar. There Was A Family Settlement Between The Various Constituents Of The Karam Chand Thapar Family As A Result Of Which Revenue-Organization/Restructuring Of The Group Dated 27Th April, 2001. The Re April, 2001. The Re-Organization Of The Group Companies & Trusts Organization Of The Group Companies & Trusts Was Made Into Four Groups, As Under, Each Headed By The Sons Of Late Lala Was Made Into Four Groups, As Under, Each Headed By The Sons Of Late Lala Was Made Into Four Groups, As Under, Each Headed By The Sons Of Late Lala K.C. Thapar. The Family Tree Of Karam Chand T K.C. Thapar. The Family Tree Of Karam Chand Thapar Family Is Explained As Hapar Family Is Explained As Under In The Form Of A Diagrammatic Chart: Under In The Form Of A Diagrammatic Chart:

section 55(2)(1), cost inflation index was to be applied with effect from 1-4-1981 instead of the year of acquisition by the assessee. 46. The Punjab & Haryana High Court in the case of DCIT v. Sushil Kumar: 231 Taxman 788 held that where capital asset was property of HUF prior to 1.4.1981 and assessee acquired absolute ownership

DCIT, CIRCLE-13(1), NEW DELHI vs. JARUL INFRASTRUCTURE PVT. LTD, NEW DELHI

In the result, the Revenue’s appeal is dismissed

Bench: Shri Shamim Yahya & Shri Anubhav Sharma[Assessment Year: 2012-13]

transfer as per provisions of section 2(47) of the Act. The AO disallowed the short term capital loss of Rs. 76,12,50,000 claimed by the appellant. In addition to the appellant's submissions, the AR has also submitted the order of Ld. CIT(A)-1, who has allowed the short term capital loss claimed by Alona Azalea

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

The appeals are allowed in the above terms, but with no orders as to costs

2. Whether AMP Expenses incurred by the Assessee in India can be treated and categorized as an international transaction under Section 92B of the Income Tax Act, 1961? 3. Whether under Chapter X of the Income Tax Act, 1961, a transfer pricing adjustment can be made by the Transfer 2015:DHC:10110-DB ITA Nos.110/2014 & 710/2015 Page

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

The appeals are allowed in the above terms, but with no orders as to costs

2. Whether AMP Expenses incurred by the Assessee in India can be treated and categorized as an international transaction under Section 92B of the Income Tax Act, 1961? 3. Whether under Chapter X of the Income Tax Act, 1961, a transfer pricing adjustment can be made by the Transfer 2015:DHC:10110-DB ITA Nos.110/2014 & 710/2015 Page

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), MEERUT, MEERUT vs. PREM SAPRA, NEW DELHI

The appeal of the revenue is dismissed

Bench: Smt. Annapurna Gupta & Ms. Madhumita Royassessment Year: 2021-22

2(47) of the Act, we are of the view that the appellants were entitled to relief under Section 54 of the Act in respect of the long term capital gain which they had earned in pursuance of transfer of their residential property being House No. 267, Sector 9-C, situated in Chandigarh and used for purchase

DCIT, CC-29, NEW DELHI vs. DHARAMPAL SATYALPAL LTD., NEW DELHI

Bench: Shri G. S. Pannu & Shri Yogesh Kumar U.S.I.T.A. No. 1977/Del/2020 (A.Y 2014-15)

47. Provisions of section 80 IA (8) provides that (8) Where any goods 39[or services] held for purposes of eligible business are transferred to any other business carried on by assessee, or where any goods 40[or services] held for purposes of any other business carried on by assessee are transferred to eligible business and, in either case, consideration

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)

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 Officer under section 92CA(1) of the Act. The Transfer Pricing Officer passed order under section 92CA

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)

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 Officer under section 92CA(1) of the Act. The Transfer Pricing Officer passed order under section 92CA

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)

price. Finally, there was a tripartite agreement between the purchaser (the assessee), the vendor, and the third party. and the purchaser was returned the earnest money as well as paid a sum of Rs. 5,00,000 'being the amount of consideration for the transfer and assignment' of his right, title and interest under the contract for sale

VACHASPATI SHARMA,GURGAON vs. ITO WARD -4(1), GURGAON

In the result, the appeal of the assessee is dismissed

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2019-20 Vachaspati Sharma Vs Ito Village – Hayatpur Garhi Ward-4 Harsaru, Hayatpur, Gurgaon Gurgaon Pan No.Fnqps2021R (Appellant) (Respondent) Appellants By Sh. Suraj Bhan Nain, Advocate Sh. K.L. Pahwa, Advocate Respondent By Ms. Sapna Bhatia, Cit Dr Date Of Hearing: 11/09/2024 Date Of Pronouncement: 21/11/2024 Order Sh. Sudhir Kumar, Jm :

47,720/- made by the Ld. Assessing Officer under the head other sources" u/s 56 of the Income-tax Act on account of interest u/s 28 of the Land Acquisition Act 1894 of Rs. 4,78,95,440/- received by the appellant during the year, which was part of enhanced compensation for compulsory acquisition of his agricultural land exempt

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

Transfer Pricing Review for the FY ended 31.03.2007 (pages 643-648, 653-654 of Paper Book). He further submitted that TNMM applied by the TPO which has been accepted by the assessee takes care of minor differences in functional profile etc. and hence this company be retained as a comparable company. 14.5 We have heard the Ld. Representatives of both

HEADSTRONG SERVICES INDIA PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal of the assessee stands partly allowed for statistical purposes in terms of our observations contained in the preceding paragraphs

Bench: Shri B. R. R. Kumar

47,41,550/- under normal provisions and Rs. 80,48,91,544/- u/s 115JB of the IT Act. The case was selected for scrutiny and notice under section 143(2) of the Act was issued. In response to the notices, Assessee filed the requisite details. 5. The assessee has applied Transactional Net Margin Method (‘TNMM’) being most appropriate method

NDTV WORLDWIDE LTD,NEW DELHI vs. DCIT 18(1), NEW DELHI

Bench: Shri G.S. Pannu & Shri Anubhav Sharmandtv Worldwide Ltd, Vs. Dcit, Okhla Industrial Estate, Circle-18(1), Phase-Ii, New Delhi New Delhi (Appellant) (Respondent) Pan: Aaccn9121G

47) of the Income Tax Act, 1961 (‘the Act’). That the CIT(A) erred on facts and in law in not appreciating that the terms of Share Purchase Agreement (‘SPA’) clearly established that the same was a conditional agreement and was contingent upon complying with certain conditions laid down therein which, inter-alia, required that shares shall stand transferred only

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

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

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\nOfficer under section 92CA(1) of the Act. The Transfer Pricing Officer passed\norder under section 92CA

TUPPERWARE INDIA PRIVATE LIMITED,NEW DELHI vs. ACIT, CIRCLE-25(1) , NEW DELHI

In the result, the appeal of the assessee for AY 2018-19 is partly allowed for statistical purposes

Bench: Shri Mahavir Singh & Shri M. Balaganesh

2% based on the fresh search undertaken by the Ld. TPO during the course of proceedings by adopting the methodology similar to that adopted by the Appellant in the transfer pricing documentation. Page 4 of 46 ITA Nos. 462 AND 2409/Del/2022 Tupperware India Private Ltd 9. That on the facts and circumstances of the case

TUPPERWARE INDIA PRIVATE LIMITED,NEW DELHI vs. DCIT,CIRCLE-25(1), NEW DELHI

In the result, the appeal of the assessee for AY 2018-19 is partly allowed for statistical purposes

Bench: Shri Mahavir Singh & Shri M. Balaganesh

2% based on the fresh search undertaken by the Ld. TPO during the course of proceedings by adopting the methodology similar to that adopted by the Appellant in the transfer pricing documentation. Page 4 of 46 ITA Nos. 462 AND 2409/Del/2022 Tupperware India Private Ltd 9. That on the facts and circumstances of the case