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 92CA. Consequently, the reference appears to be invalid, and the transfer pricing and subsequent proceedings also appear to be time barred. In this context it is necessary to make following submissions – (a) time barring being a mandate to the forum, Hon’ble Tribunal may have to decide this preliminary aspect (b) assuming time barring aspect is decided in favour

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

transfer of electricity from eligible unit to non-eligible unit is INR\n6.45 per KWH therefore, it was claimed that it is at ALP. The TPO\nhas obtained the rates from IEX and asked the assessee as to why\nExternal CUP method should not be applied, and sale rate of power\nshould not be taken at average price at which

DCM SHRIRAM LIMITED,DELHI vs. ASSESSMENT UNIT, DELHI

transfer of electricity from eligible unit to non-eligible unit is INR\n6.45 per KWH therefore, it was claimed that it is at ALP. The TPO\nhas obtained the rates from IEX and asked the assessee as to why\nExternal CUP method should not be applied, and sale rate of power\nshould not be taken at average price at which

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

transfer of electricity from eligible unit to non-eligible unit is INR\n6.45 per KWH therefore, it was claimed that it is at ALP. The TPO\nhas obtained the rates from IEX and asked the assessee as to why\nExternal CUP method should not be applied, and sale rate of power\nshould not be taken at average price at which

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

transfer of electricity from eligible unit to non-eligible unit is INR\n6.45 per KWH therefore, it was claimed that it is at ALP. The TPO\nhas obtained the rates from IEX and asked the assessee as to why\nExternal CUP method should not be applied, and sale rate of power\nshould not be taken at average price at which

DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., DUBLIN, IRELAND

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 182 of the ICA defines an agent as ‘a person who is employed to do any act for another or to represent another in dealings with third persons’. Thus, The relationship of an agency exists where one person has an authority or capacity to create legal relations between a person occupying the position of principal and third parties

DCIT, CIRCLE- 1(1)(1), INTERNATIONAL TAXATION, NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., NEW DELHI

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 182 of the ICA defines an agent as ‘a person who is employed to do any act for another or to represent another in dealings with third persons’. Thus, The relationship of an agency exists where one person has an authority or capacity to create legal relations between a person occupying the position of principal and third parties

DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., DUBLIN, IRELAND

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 182 of the ICA defines an agent as ‘a person who is employed to do any act for another or to represent another in dealings with third persons’. Thus, The relationship of an agency exists where one person has an authority or capacity to create legal relations between a person occupying the position of principal and third parties

ADOBE SYSTEMS SOFTWARE IRELAND LTD.,IRELAND vs. DCIT, CIRCLE- 1(1)(1), INTERNATIONAL TAXATION, NEW DELHI

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 182 of the ICA defines an agent as ‘a person who is employed to do any act for another or to represent another in dealings with third persons’. Thus, The relationship of an agency exists where one person has an authority or capacity to create legal relations between a person occupying the position of principal and third parties

DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., DUBLIN, IRELAND

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 182 of the ICA defines an agent as ‘a person who is employed to do any act for another or to represent another in dealings with third persons’. Thus, The relationship of an agency exists where one person has an authority or capacity to create legal relations between a person occupying the position of principal and third parties

DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., DUBLIN, IRELAND

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 182 of the ICA defines an agent as ‘a person who is employed to do any act for another or to represent another in dealings with third persons’. Thus, The relationship of an agency exists where one person has an authority or capacity to create legal relations between a person occupying the position of principal and third parties

DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., DUBLIN, IRELAND

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 182 of the ICA defines an agent as ‘a person who is employed to do any act for another or to represent another in dealings with third persons’. Thus, The relationship of an agency exists where one person has an authority or capacity to create legal relations between a person occupying the position of principal and third parties

ADOBE SYSTEMS SOFTWARE IRELAND LTD.,IRELAND vs. DCIT, CIRCLE- 1(1)(1), INTERNATIONAL TAXATION, NEW DELHI

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 182 of the ICA defines an agent as ‘a person who is employed to do any act for another or to represent another in dealings with third persons’. Thus, The relationship of an agency exists where one person has an authority or capacity to create legal relations between a person occupying the position of principal and third parties

ADOBE SYSTEMS SOFTWARE IRELAND LTD.,DUBLIN, IRELAND vs. DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 182 of the ICA defines an agent as ‘a person who is employed to do any act for another or to represent another in dealings with third persons’. Thus, The relationship of an agency exists where one person has an authority or capacity to create legal relations between a person occupying the position of principal and third parties

DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., DUBLIN, IRELAND

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 182 of the ICA defines an agent as ‘a person who is employed to do any act for another or to represent another in dealings with third persons’. Thus, The relationship of an agency exists where one person has an authority or capacity to create legal relations between a person occupying the position of principal and third parties

ADOBE SYSTEMS SOFTWARE IRELAND LTD.,IRELAND vs. DCIT, CIRCLE- 1(1)(1), INTERNATIONAL TAXATION, NEW DELHI

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 182 of the ICA defines an agent as ‘a person who is employed to do any act for another or to represent another in dealings with third persons’. Thus, The relationship of an agency exists where one person has an authority or capacity to create legal relations between a person occupying the position of principal and third parties

ADOBE SYSTEMS SOFTWERE IRELAND LIMITED,DUBLIN 24, IRELAND vs. DCIT CIRCLE- 1(1)(1), INTERNATIONAL TAXATION , NEW DELHI

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 182 of the ICA defines an agent as ‘a person who is employed to do any act for another or to represent another in dealings with third persons’. Thus, The relationship of an agency exists where one person has an authority or capacity to create legal relations between a person occupying the position of principal and third parties

DCIT, INTERNATIONAL TAXATION, CIRCLE- 1(1)(1), NEW DELHI vs. ADOBE SYSTEMS SOFTWARE IRELAND LTD., DUBLIN, IRELAND

In the result, appeals by the assessee stand allowed in terms of the above order and the Revenue’s appeal stand dismissed as above

Bench: Shri Shamim Yahya & Shri Chandra Mohan Garg

Section 182 of the ICA defines an agent as ‘a person who is employed to do any act for another or to represent another in dealings with third persons’. Thus, The relationship of an agency exists where one person has an authority or capacity to create legal relations between a person occupying the position of principal and third parties