THE COMMISSIONER OF INCOME TAX - INTERNATIONAL TAXATION -3 vs. TRAVELPORT LP

Bench: The Itat Was Preferred By The Respondent/Assessee Against Order Dated 21.06.2019 Framed Under Sections 144C(13) Read With Section 147, 143(3) Of The Act. 3. The Tribunal Allowed The Appeal Of The Respondent By Stating In Paragraphs 19, 20, 21, 22, 23 & 24 As Under: “19. Facts Of The Case In Hand Show That No Order Has Been' Signed By:Pradeep Sharma Signing Date:16.09.2025 11:42:21 Signature Not Verified

Transfer Pricing Officer. Therefore, the first condition of section 144C(15)(b) of the Act is not satisfied. Thus, i t requires to be seen whether the assessee can fit into the definition of a foreign company as provide du/s 144C(15)(b)(ii) of the Act. As per the definition of foreign company under section

GENPACT SERVICES LLC,GURGAON vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE - INT TAX 1(3)(1), DELHI

In the result, appeal of the assessee is partly allowed

Bench: Shri Prakash Chand Yadav\Nand\Nshri Brajesh Kumar Singh\N\Nita No. 4477/Del/2024\N[Assessment Year: 2020-21]\N\N| Genpact Services Llc,\Nplot 22A & B, Sector 18,\Nudyog Vihar,\Ngurgaon, Haryana-122002\Npan-Aaccg3353P\Nappellant\N|\Nassistant Commissioner Of Income\Ntax, Circle-International Tax-1(3)(1),\Nvs Delhi-110002\Nrespondent\N\N| Appellant By\Nshri Vishal Kalra, Adv.,\Nms. Reema Malik, Adv.& Ms.\Nsnigdha Gautam, Adv.\Nrespondent By\Nshri S.K. Jadhav, Cit Dr\N\Ndate Of Hearing\N30.07.2025\Ndate Of Pronouncement\N31.07.2025\N\Norder\N\Nper Brajesh Kumar Singh, Am,\Nthis Appeal By The Assessee Is Directed Against The Order Of The\Nassessing Officer Dated 29.07.2024 Passed U/S 143(3) R.W.S.144C(13) Of\Nthe Income Tax Act, 1961 (Hereinafter ‘The Act') In Pursuance To The\Ndirections Of Dispute Resolution Panel Dated 25.06.2024 Pertaining To\N Assessment Year 2020-21.\N2. The Relevant Facts Are That The Assessee Is An Indian Branch Office Of\Ngenpact Llc, A Usa Company. The Assessee Is A Service Provider\Nrendering Off-Shore Support Services Akin To Bpo Services, Including\Ncollections/Analytics Call Centre Services & Other Back-Office Support\Nservices To Its Aes. The Assessee Is Responsible For Rendering The\Ndesignated Bpo / Collections Services From Its Facility / Infrastructure In\Nindia. As For Assessment Year 2020-21, The Assessee Filed Its Return Of\Nincome (Roi') Declaring An Income Of Inr 20,57,10,540/- On 07.01.2021.\Nduring The Course Of Scrutiny, The Assessing Officer Made A Reference U/S\N92Ca Of The Act To The Transfer Pricing Officer (Tpo') To Determine The\Narm'S Length Price (‘Alp') In Respect Of International Transaction Entered\Ninto By The Assessee.\N2.

22A and B, Sector 18,\nUdyog Vihar,\nGurgaon, Haryana-122002\nPAN-AACCG3353P\nAppellant\n|\nAssistant Commissioner of Income\nTax, Circle-International Tax-1(3)(1),\nVs Delhi-110002\nRespondent\n\n| Appellant by\nShri Vishal Kalra, Adv.,\nMs. Reema Malik, Adv.& Ms.\nSnigdha Gautam, Adv.\nRespondent by\nShri S.K. Jadhav, CIT DR\n\nDate of Hearing\n30.07.2025\nDate of Pronouncement

GENPACT SERVICES LLC,GURGAON vs. ACIT, CIRCLE-1(3)(1), INTERNATIONAL TAXATION, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.Genpact Services Llc, Vs. Acit, Plot No. 22A & B, Circle-1(3)(1), Sector-18, Udyog Vihar, International Taxation, Gurgaon, Haryana New Delhi (Appellant) (Respondent) Pan: Aaccg3353P

22A and B, Circle-1(3)(1), Sector-18, Udyog Vihar, International Taxation, Gurgaon, Haryana New Delhi (Appellant) (Respondent) PAN: AACCG3353P Assessee by : Shri Vishal Kalra, Adv Ms. Reema Malik, Adv Ms. Snigdha Gautam, Adv Revenue by: Shri Rajesh Kumar, CIT DR Date of Hearing 23/01/2024 Date of pronouncement 19/04/2024 O R D E R PER M. BALAGANESH

GENPACT SERVICES LLC,GURGAON vs. ACIT,CIRCLE-1(3)(1) INT. TAXATION, DELHI

In the result, the Assessee’s appeal is allowed

Bench: Shri Shamim Yahya & Shri Vimal Kumara.Yr. : 2018-19 M/S Genpact Services Llc Vs. Assistant Commissioner Of Plot No. 22A & B, Sector-18, Income Tax, Udyog Vihar, Circle – Int. Tax 1(3)(1), Gurgaon, New Delhi Haryana-122002 (Pan: Aaccg3353P) (Appellant) (Respondent)

22A & B, Sector-18, Income Tax, Udyog Vihar, Circle – Int. Tax 1(3)(1), Gurgaon, New Delhi Haryana-122002 (PAN: AACCG3353P) (APPELLANT) (RESPONDENT) Appellant by : Shri Vishal Kalra, Adv. & Ms. Reema Malik, Adv. Respondent by : Shri Zafrul Haque Tanweer, CIT(DR) Date of hearing : 10.07.2024 Date of pronouncement : 09.08.2024 ORDER PER SHAMIM YAHYA, AM : The Assessee has filed this Appeal

GENPACT SERVICES LLC,GURGAON vs. ACIT, CIRCLE INT. TAXATION 1(3)(1), NEW DELHI

In the result, appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Brajesh Kumar Singh[Assessment Year: 2019-20]

22A AND B, Sector 18, Tax, Circle-International Tax-1(3)(1), Udyog Vihar, Vs Delhi-110002 Gurgaon, Haryana-122002 PAN-AACCG3353P Appellant Respondent Appellant by Shri Vishal Kalra, Adv., Ms. Reema Grewal, CA & Ms. Snigdha Gautam, Adv. Respondent by Ms. Prajna Paramita, CIT DR Date of Hearing 22.04.2025 Date of Pronouncement 06.06.2025 ORDER PER BRAJESH KUMAR SINGH, AM, This

JITF URBAN INFRASTRUCTURE SERVICES LTD,NEW DELHI vs. DCIT, CIRCLE-13(2), NEW DELHI

Appeals are partly allowed

Bench: Shri Amit Shukla & Dr. B.R.R. Kumar

Transfer Pricing proceedings, the limitation in the said case got extended by one year. The Assessing officer issued a commission u/s 131(1)(d) of the Act to the ADIT (Inv.), Unit - 2, Raipur vide email dated 21/12/2019 to make certain enquiries on the above-mentioned registered office address of the two lender companies. The commission has been reproduced

JINDAL QUALITY TUBULAR LTD,NEW DELHI vs. DCIT CIRCLE-13(2), NEW DELHI

Appeals are partly allowed

Bench: Shri Amit Shukla & Dr. B.R.R. Kumar

Transfer Pricing proceedings, the limitation in the said case got extended by one year. The Assessing officer issued a commission u/s 131(1)(d) of the Act to the ADIT (Inv.), Unit - 2, Raipur vide email dated 21/12/2019 to make certain enquiries on the above-mentioned registered office address of the two lender companies. The commission has been reproduced

JINDAL FITTINGS LTD,NEW DELHI vs. DCIT CIRCLE=13(2), NEW DELHI

Appeals are partly allowed

Bench: Shri Amit Shukla & Dr. B.R.R. Kumar

Transfer Pricing proceedings, the limitation in the said case got extended by one year. The Assessing officer issued a commission u/s 131(1)(d) of the Act to the ADIT (Inv.), Unit - 2, Raipur vide email dated 21/12/2019 to make certain enquiries on the above-mentioned registered office address of the two lender companies. The commission has been reproduced

JINDAL ITF LTD.,NEW DELHI vs. DCIT, CIRCLE- 13(2), NEW DELHI

Appeals are partly allowed

Bench: Shri Amit Shukla & Dr. B.R.R. Kumar

Transfer Pricing proceedings, the limitation in the said case got extended by one year. The Assessing officer issued a commission u/s 131(1)(d) of the Act to the ADIT (Inv.), Unit - 2, Raipur vide email dated 21/12/2019 to make certain enquiries on the above-mentioned registered office address of the two lender companies. The commission has been reproduced

ACIT, JAMMU vs. DR KARAN SINGH, JAMMU

In the result, all the fours appeals filed by the Revenue are dismissed and the three Cross Objections as well as the ground as per Rule 27 are allowed

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

22A) of the Act and thus for the purposes of section 55(2)(b)(ii) of the Act it is a fair market value under the Income Tax Act which has to be adopted; 33.1. Ld. Counsel for the assessee referring to the following decisions submitted that the revenue cannot set up a new case for the first time before

ACIT, JAMMU vs. SH VIKRAMADITYA SINGH, JAMMU

In the result, all the fours appeals filed by the Revenue are dismissed and the three Cross Objections as well as the ground as per Rule 27 are allowed

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

22A) of the Act and thus for the purposes of section 55(2)(b)(ii) of the Act it is a fair market value under the Income Tax Act which has to be adopted; 33.1. Ld. Counsel for the assessee referring to the following decisions submitted that the revenue cannot set up a new case for the first time before

ACIT, CIR-II, JAMMU vs. SMT. YASHORAJYA LAXMI, JAMMU

In the result, all the fours appeals filed by the Revenue are dismissed and the three Cross Objections as well as the ground as per Rule 27 are allowed

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

22A) of the Act and thus for the purposes of section 55(2)(b)(ii) of the Act it is a fair market value under the Income Tax Act which has to be adopted; 33.1. Ld. Counsel for the assessee referring to the following decisions submitted that the revenue cannot set up a new case for the first time before

ACIT, JAMMU vs. SH M.K. AJAT SHATRU, JAMMU

In the result, all the fours appeals filed by the Revenue are dismissed and the three Cross Objections as well as the ground as per Rule 27 are allowed

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

22A) of the Act and thus for the purposes of section 55(2)(b)(ii) of the Act it is a fair market value under the Income Tax Act which has to be adopted; 33.1. Ld. Counsel for the assessee referring to the following decisions submitted that the revenue cannot set up a new case for the first time before