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

Section 92F (v), an international transaction could include an arrangement, understanding or action in concert, this cannot be a matter of inference. There has to be some tangible evidence on record to show that two parties have "acted in concert". XXX XXX XXX 37. The provisions under Chapter X do envisage a 'separate entity concept'. In other words, there cannot

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 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

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

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

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. 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-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

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

Transfer Pricing (“TP”) documentation requirements. 4. The learned TPO has applied filters which are not justified in the facts and circumstances of the case. 5. The learned AO / TPO/ DRP have erred by rejecting certain comparable companies identified by the Appellant for having different accounting year (i.e. having accounting year other than March 31 or companies whose financial statements were

DCM SHRIRAM LIMITED,DELHI vs. ASSESSMENT UNIT, DELHI

transfer pricing proceedings u/s 92CA of the Act are\nvitiated being void-ab-initio as no valid notice u/s 143(2) of the Act was\nserved on the assessee within the statutory time limit prescribed under\nthat sub-section (viz. 30th September, 2017).\n13. Without prejudice to above, the Id. AO has grossly erred in law and\non facts

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

transfer pricing proceedings u/s 92CA of the Act are\nvitiated being void-ab-initio as no valid notice u/s 143(2) of the Act was\nserved on the assessee within the statutory time limit prescribed under\nthat sub-section (viz. 30th September, 2017).\n13. Without prejudice to above, the Id. AO has grossly erred in law and\non facts

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

transfer pricing proceedings u/s 92CA of the Act are\nvitiated being void-ab-initio as no valid notice u/s 143(2) of the Act was\nserved on the assessee within the statutory time limit prescribed under\nthat sub-section (viz. 30th September, 2017).\n\n13. Without prejudice to above, the Id. AO has grossly erred in law and\non facts

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

transfer pricing proceedings u/s 92CA of the Act are\nvitiated being void-ab-initio as no valid notice u/s 143(2) of the Act was\nserved on the assessee within the statutory time limit prescribed under\nthat sub-section (viz. 30th September, 2017).\n\n13. Without prejudice to above, the Id. AO has grossly erred in law and\non facts

TRAVELPORT LP,GEORGIA USA vs. DCIT, INTERNATIONAL TAXATION CIRCLE-3(1)(1), NEW DELHI

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

Bench: Shri N.K. Billaiya & Shri Anubhav Sharma

234C of the Act. The above grounds are without prejudice to each other. The Appellant craves leave to add, alter, amend, rescind, modify or withdraw any ground(s) herein above or produce further documents either before or at the time of hearing of this appeal.” 3. Referring to the issues vide Ground No. 2, the ld. counsel for the assessee

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]

234C of the Act. 37. That the NFAC erred in levying interest under section 234D of the Act. 38. That the NFAC erred in withdrawing/ reducing interest under section 244A of the Act. 39. That the NF'AC erred in initiating penalty under section 271AA of the Act. 40. That the NFAC erred in initiating penalty under section 270AA

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