SRF LIMITED ,DELHI vs. ACIT, CIRCLE-10(1), DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

237, 2nd Floor, Mayur Place, Mayur Vihar Phase 1 Ext., New Delhi – 110 091. (PAN : AAACS0206P) (APPELLANT) (RESPONDENT) ASSESSEE BY : Shri Pradeep Dinodia, CA Shri Ravi Kumar, CA Shri Hemant Kumar, CA Shri Shubham, CA REVENUE BY : Shri S.K. Jadhav, CIT DR Date of Hearing : 15.10.2025 Date of Order : 12.12.2025 O R D E R PER S. RIFAUR RAHMAN, ACCOUNTANT

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

237, 2nd Floor, Mayur Place, Mayur Vihar Phase 1 Ext., New Delhi – 110 091. (PAN : AAACS0206P) (APPELLANT) (RESPONDENT) ASSESSEE BY : Shri Pradeep Dinodia, CA Shri Ravi Kumar, CA Shri Hemant Kumar, CA Shri Shubham, CA REVENUE BY : Shri S.K. Jadhav, CIT DR Date of Hearing : 15.10.2025 Date of Order : 12.12.2025 O R D E R PER S. RIFAUR RAHMAN, ACCOUNTANT

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

237, 2nd Floor, Mayur Place, Mayur Vihar Phase 1 Ext., New Delhi – 110 091. (PAN : AAACS0206P) (APPELLANT) (RESPONDENT) ASSESSEE BY : Shri Pradeep Dinodia, CA Shri Ravi Kumar, CA Shri Hemant Kumar, CA Shri Shubham, CA REVENUE BY : Shri S.K. Jadhav, CIT DR Date of Hearing : 15.10.2025 Date of Order : 12.12.2025 O R D E R PER S. RIFAUR RAHMAN, ACCOUNTANT

MCKINSEY KNOWLEDGE CENTRE INDIA PVT. LTD.,HARYANA vs. DCIT CIRCLE 16(1) , DELHI

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

Bench: Shri Shamim Yahya & Shri Sudhir Kumarmckinsey Knowledge Centre India Pvt. Ltd., Vs. Dcit, Circle 16 (1), 3Rd Floor, Block Iii, Delhi. Vatika Business Park, Sector 49, Sohna Road, Gurgaon – 122 018 (Haryana). (Pan : Aaccm2356G) (Appellant) (Respondent) Assessee By : Shri Porus Kaka, Sr. Advocate Shri Divesh Chawla, Advocate Revenue By : Shri Rajesh Kumar, Cit Dr Date Of Hearing : 24.04.2024 Date Of Order : 04.06.2024 Order Per Shamim Yahya: This Appeal By The Assessee Is Directed Against The Order Of The Assessing Officer Dated 21.01.2022 Pursuant To The Directions Issued By The Drp For The Assessment Year 2017-18. 2. Grounds Of Appeal Taken By The Assessee Read As Under :-

transfer pricing adjustment related to notional interest ought to be deleted.” “SUBMISSIONS BY THE LD. DR FOR THE REVENUE : Kindly refer to the above. The case was heard on 24.04.2024 and during the course of hearing, both the sides argued the matter. Further, both the sides were given the liberty to file written submissions, and in line with the directions

AYATNA REALTY PVT. LTD.,NEW DELHI vs. ACIT, CIRCLE-3(2), NEW DELHI

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

Bench: Shri Vikas Awasthy & Shri Manish Agarwalm/S Wrigley India Private Dcit, Limited Circle-27(2), 206, Okhla Industrial Vs. New Delhi. Estate, Phase Iii, New Delhi-110020 Pan-Aaacw1789P (Appellant) (Respondent) Joint Cit (Osd), M/S Wrigley India Private Circle-27(2), Limited, New Delhi Vs. 206, Okhla Industrial Estate, Phase Iii, New Delhi-110020 Pan-Aaacw1789P (Appellant) (Respondent)

Section 92F(5) of the Act, if ITA No.1293 to1295/Del/2022 there is an arrangement, understanding or action in concert, whether or not such arrangement, is in action formal or in writing which shows to substantiate in a transaction between two AEs, transfer pricing provisions would apply, and the transaction would qualify as an international transaction. Further, in the instant case

AYATNA REALTY PVT. LTD.,NEW DELHI vs. ACIT, CIRCLE-3(2), NEW DELHI

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

Bench: Shri Vikas Awasthy & Shri Manish Agarwalm/S Wrigley India Private Dcit, Limited Circle-27(2), 206, Okhla Industrial Vs. New Delhi. Estate, Phase Iii, New Delhi-110020 Pan-Aaacw1789P (Appellant) (Respondent) Joint Cit (Osd), M/S Wrigley India Private Circle-27(2), Limited, New Delhi Vs. 206, Okhla Industrial Estate, Phase Iii, New Delhi-110020 Pan-Aaacw1789P (Appellant) (Respondent)

Section 92F(5) of the Act, if ITA No.1293 to1295/Del/2022 there is an arrangement, understanding or action in concert, whether or not such arrangement, is in action formal or in writing which shows to substantiate in a transaction between two AEs, transfer pricing provisions would apply, and the transaction would qualify as an international transaction. Further, in the instant case

GREENLAND FINANCE AND LEASING P. LTD.,DELHI vs. ITO, NEW DELHI

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

Bench: Shri Vikas Awasthy & Shri Manish Agarwalm/S Wrigley India Private Dcit, Limited Circle-27(2), 206, Okhla Industrial Vs. New Delhi. Estate, Phase Iii, New Delhi-110020 Pan-Aaacw1789P (Appellant) (Respondent) Joint Cit (Osd), M/S Wrigley India Private Circle-27(2), Limited, New Delhi Vs. 206, Okhla Industrial Estate, Phase Iii, New Delhi-110020 Pan-Aaacw1789P (Appellant) (Respondent)

Section 92F(5) of the Act, if ITA No.1293 to1295/Del/2022 there is an arrangement, understanding or action in concert, whether or not such arrangement, is in action formal or in writing which shows to substantiate in a transaction between two AEs, transfer pricing provisions would apply, and the transaction would qualify as an international transaction. Further, in the instant case

GREENLAND FINANCE AND LEASING P. LTD.,DELHI vs. ITO, NEW DELHI

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

Bench: Shri Vikas Awasthy & Shri Manish Agarwalm/S Wrigley India Private Dcit, Limited Circle-27(2), 206, Okhla Industrial Vs. New Delhi. Estate, Phase Iii, New Delhi-110020 Pan-Aaacw1789P (Appellant) (Respondent) Joint Cit (Osd), M/S Wrigley India Private Circle-27(2), Limited, New Delhi Vs. 206, Okhla Industrial Estate, Phase Iii, New Delhi-110020 Pan-Aaacw1789P (Appellant) (Respondent)

Section 92F(5) of the Act, if ITA No.1293 to1295/Del/2022 there is an arrangement, understanding or action in concert, whether or not such arrangement, is in action formal or in writing which shows to substantiate in a transaction between two AEs, transfer pricing provisions would apply, and the transaction would qualify as an international transaction. Further, in the instant case

DCIT, CIRCLE-25(1), NEW DELHI vs. WRIGLEY INDIA P.LTD, NEW DELHI

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

Section 92F(5) of the Act, if\nthere is an arrangement, understanding or action in concert, whether or not\nsuch arrangement, is in action formal or in writing which shows to substantiate\nin a transaction between two AEs, transfer pricing provisions would apply, and\nthe transaction would qualify as an international transaction. Further, in the\ninstant case, there

WRIGLEY INDIA PVT. LTD.,206, OKHLA INDUSTRIAL ESTATE, PHASE-3,NEW DELHI-110020 vs. DCIT, CIRCLE 27(2), NEW DELHI

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

Section 92F(5) of the Act, if\n\n13\nITA Nos.667 & 702, 952 & 953/Del/2022\nITA No.1293 to1295/Del/2022\n\nthere is an arrangement, understanding or action in concert, whether or not\nsuch arrangement, is in action formal or in writing which shows to substantiate\nin a transaction between two AEs, transfer pricing provisions would apply, and\nthe transaction would qualify

WRIGLEY INDIA PRIVATE LIMITED,DELHI vs. ACIT,CIRCLE-27(2), DELHI

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

Section 92F(5) of the Act, if\nthere is an arrangement, understanding or action in concert, whether or not\nsuch arrangement, is in action formal or in writing which shows to substantiate\nin a transaction between two AEs, transfer pricing provisions would apply, and\nthe transaction would qualify as an international transaction. Further, in the\ninstant case, there

DCIT, CIRCLE- 25(1), NEW DELHI vs. WRIGLEY INDIA PVT. LTD., NEW DELHI

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

Section 92F(5) of the Act, if\n13\nITA Nos.667 & 702, 952 & 953/Del/2022\nITA No. 1293 to 1295/Del/2022\nthere is an arrangement, understanding or action in concert, whether or not\nsuch arrangement, is in action formal or in writing which shows to substantiate\nin a transaction between two AEs, transfer pricing provisions would apply, and\nthe transaction would qualify

JCIT, CIRCLE-27(2), NEW DELHI vs. WRIGLEY INDIA PVT. LTD., NEW DELHI

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

Section 92F(5) of the Act, if\nthere is an arrangement, understanding or action in concert, whether or not\nsuch arrangement, is in action formal or in writing which shows to substantiate\nin a transaction between two AEs, transfer pricing provisions would apply, and\nthe transaction would qualify as an international transaction. Further, in the\ninstant case, there

DCIT, CIRCLE-25(1), NEW DELHI vs. WRIGLEY INDIA P.LTD, NEW DELHI

Section 92F(5) of the Act, if\nthere is an arrangement, understanding or action in concert, whether or not\nsuch arrangement, is in action formal or in writing which shows to substantiate\nin a transaction between two AEs, transfer pricing provisions would apply, and\nthe transaction would qualify as an international transaction. Further, in the\ninstant case, there

WRIGLEY INDIA PRIVATE LIMITED,DELHI vs. ACIT,CIRCLE-27(2), DELHI

Section 92F(5) of the Act, if\n\nthere is an arrangement, understanding or action in concert, whether or not\nsuch arrangement, is in action formal or in writing which shows to substantiate\nin a transaction between two AEs, transfer pricing provisions would apply, and\nthe transaction would qualify as an international transaction. Further, in the\ninstant case, there

TECHNIP INDIA LTD.,NOIDA vs. ADDL.CIT, SPECIAL RANGE- 9, NEW DELHI

In the result, Appeal No.6390/Del/2017 is partly allowed as per above terms

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarita No. 6390/Del/2017 Assessment Year: 2013-14 Ita No. 9852/Del/2019 Assessment Year: 2015-16 Technip Energies India Vs. Additional Commissioner Of Limited, ( Formerly Known As Income Tax, Technip India Limited), Special Range-9, A-4, Sector 1, Institutional New Delhi Area, Noida – 201 301 Pan No. Aaack3349R (Appellant) (Respondent)

section 92(3) of the Act, if after application of the transfer pricing principles the income of the Appellant is reduced then the transfer pricing provision will not be applicable. It is submitted that the said benefit of set-off has been provided to the Appellant by the CIT(A) for AY 2015-16, basis which adjustment was deleted

TECHNIP INDIA LIMITED,NEW DELHI vs. ACIT, SPL RANGE-9, NEW DELHI

In the result, Appeal No.6390/Del/2017 is partly allowed as per above terms

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarita No. 6390/Del/2017 Assessment Year: 2013-14 Ita No. 9852/Del/2019 Assessment Year: 2015-16 Technip Energies India Vs. Additional Commissioner Of Limited, ( Formerly Known As Income Tax, Technip India Limited), Special Range-9, A-4, Sector 1, Institutional New Delhi Area, Noida – 201 301 Pan No. Aaack3349R (Appellant) (Respondent)

section 92(3) of the Act, if after application of the transfer pricing principles the income of the Appellant is reduced then the transfer pricing provision will not be applicable. It is submitted that the said benefit of set-off has been provided to the Appellant by the CIT(A) for AY 2015-16, basis which adjustment was deleted

ARIBA INC,NEW DELHI vs. ADIT (INTL TAXATION), NEW DELHI

In the result, all these appeals filed by the assessee stand partly

Section 237 of the Indian Contract Act provides that an agency by holding out is created only if the principal, by words or conduct, induced third persons to believe that acts done and obligations incurred by an agent were within the scope of the agent's authority. In the present case, no material/ evidence has been brought on record