DCIT CENTRAL CIRCLE-14, NEW DELHI vs. SH. VIJAY KUMAR SONI, NEW DELHI

The appeal of the Revenue is dismissed as infructuous

Bench: Dr. B. R. R. Kumarsh. Sudhir Kumarita No. 1883/Del/2023 : Asstt. Year : 2017-18 Bijay Kumar Soni, Vs Dcit, C/O Anil Jain Dd & Co., Central Circle-14, 611, Surya Kiran Building, 19, New Delhi-110055 K. G. Marg, New Delhi-110001 (Appellant) (Respondent) Pan No. Aolps5917H Ita No. 2144/Del/2023 : Asstt. Year : 2017-18 Dcit, Vs Bijay Kumar Soni, Central Circle-14, 61/14, Block No. 61, Ram Jas, New Delhi-110055 Karol Bagh, New Delhi-110005 (Appellant) (Respondent) Pan No. Aolps5917H Assessee By : Sh. Anil Jain, Ca Revenue By : Ms. Monika Dhami, Cit-Dr Date Of Hearing: 01.08.2023 Date Of Pronouncement: 06.09.2023 Order Per Dr. B. R. R. Kumar:

1), (1A), (2), (3) and (3A)], shall be extended by twelve months. (5) Where effect to an order under section 250 or section 254 or section 260 or section 262 or section 263 or section 264 is to be given by the Assessing Officer 47[or the Transfer Pricing

EBRO INDIA PVT.LTD. ,DELHI vs. ACIT CIRCLE-7(1), DELHI

In the result, the ground no 4 raised by the assessee is allowed

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Accountant Member)

Transfer Pricing Officer (TPO) under section 92CA of the Act. During such proceedings, - the TPO, vide notice dated 25.02.2021, inter-alia, required the assessee to submit the details of change in shareholding structure and other international transactions [refer pages 97-98 of paperbook]; and - in response thereto, the appellantvide reply dated 07.07.2021 submitted (as Annexure-11 to the reply

RAKESH KUMAR GUPTA,DELHI vs. LD. ITO, WARD 35(1), DELHI, DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2021-22] Rakesh Kumar Gupta, Income Tax Officer, Ward-35(1), B-2/38, Ground Floor, E-2, Civic Centre, Delhi-110002 Ashok Vihar, Phase-Ii, Vs Delhi-110052 Pan-Aafhr8657H Appellant Respondent

250 of the Act without granting virtual / physical hearing. 3. At the outset, the ld. Counsel for the assessee vehemently argued that the notice u/s 270A dated 21.12.2022 issued by the Revenue is infructuous on account of non-specification of the limb for imposing penalty in the show-cause notice. It was urged that all the grounds of the appeal

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

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

pricing were partly allowed and restored to the CIT(A) for further examination.", "result": "Partly Allowed", "sections": [ "250", "143(2)", "142(1)", "92CA(1)", "92CA(3)", "36(2)", "10B(1)(e)(iii)", "92C(2)", "10B(4)", "46A" ], "issues": "The key issues involved are the validity of transfer

JET LITE (INDIA) LTD.,MUMBAI vs. DCIT, CENTRAL CIRCLE-6 (NOW CC-1), MUMBAI

In the result, the appeal of the assessee is dismissed

Bench: Shri M. Balaganesh & Shri Anubhav Sharmajet Lite (India) Ltd, Vs. Dcit, 13, Community Central Circle-6, Centre, Yusuf Sarai, (Now Cc-1), New Delhi New Delhi (Appellant) (Respondent) Pan:Aadcs4480L

250 of the I.T. Act for both upholding the penalty order passed by the learned A.O. (against which appeal was filed) as well as enhancing the penalty (which was not the subject matter of the appeal) in contravention to the law u/s. 271(1)(c) r.w.s. 274 of the L.T. Act requiring separate orders to be passed

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)

250 of the Income Tax Act, 1961 ( hereinafter referred as “the Act”) arising out of orders dated 02.03.2006 and 18.12.2006 of the Assistant Commissioner of Income Tax, Company Circle- II(2), Chennai-34 (hereinafter referred as “Ld. AO") for the Act for assessment year 2003-04 and 2004-05 respectively. ITA No.3195 & 3196/Del/2017 2. Both the appeals involve similar facts

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)

250 of the Income Tax Act, 1961 ( hereinafter referred as “the Act”) arising out of orders dated 02.03.2006 and 18.12.2006 of the Assistant Commissioner of Income Tax, Company Circle- II(2), Chennai-34 (hereinafter referred as “Ld. AO") for the Act for assessment year 2003-04 and 2004-05 respectively. ITA No.3195 & 3196/Del/2017 2. Both the appeals involve similar facts

AKSHAY KHETTERPAL,NEW DELHI vs. ACIT, CIRCLE- 41(1), NEW DELHI

In the result, the Appeal filed by the Assessee is partly allowed

Bench: Shri R.K.Panda & Shri N. K. Choudhryakshaykhetterpal, Vs. Acit, C/O. Surindermahajan& Circle-41(1), Associates, A-134, Defence New Delhi Colony, New Delhi Pan: Bhupk0131J (Appellant) (Respondent)

250(6) of the Income-tax Act, 1961 (in short “the Act”), for the assessment year 2015-16, whereby the assessment order passed by the AO u/s 143(3) of the Act was upheld. 2. Brief facts of the case are that the Assessee is engaged in the business of importing “used digital multifunctional printer and copying machines” and during

GREEN INFRA WIND FARM ASSET LTD.,GURUGRAM vs. ACIT, CIRCLE 10(2), NEW DELHI

In the result, the appeal of the assessee is partly allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2016-17] Green Infra Wind Farm Asset Ltd., Vs Acit, 5Th Floor, Tower C, Building No.8, Circle-10(2), Dlf Cyber City, Gurugram, New Delhi. Haryana-122002. Pan-Aaecg4080H Appellant Respondent Appellant By Shri Vartik Chokshi, Ca & Shri Biren Shah, Ca Respondent By Shri Rajesh Kumar Dhanesta, Sr.Dr Date Of Hearing 23.04.2025 Date Of Pronouncement 04.07.2025 Order

250 of the Income Tax Act, 1961 [“the Act”] arising from the assessment order dated 17.12.2018 passed u/s 143(3) of the Act pertaining to Assessment Year 2016-17. 2. Brief facts of the case are that the assessee is a company, engaged in the business of generation of electricity through wind energy and is operating as a renewable energy

TUPPERWARE INDIA PVT. LTD.,NEW DELHI vs. ADDL. CIT, SPECIAL RANGE- 9, NEW DELHI

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri R.K. Panda & Ms. Astha Chandraassessment Year: 2013-14

transfer pricing study report where the type of services rendered and received by the assesee is shown along with basis of the allocation, details of services availed, manner in which services rendered and details of benefit derived is mentioned. He further referred to page No. 250 of the paper book which are bills for the services availed by the assesee

DY. COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-I NOIDA, NOIDA vs. M/S RUDRA BUILDWELL HOMES PVT. LTD., DELHI

Accordingly, all the grounds of appeal taken by Revenue are dismissed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwaldy. Cit, M/S Rudra Buildwell Homes Central Circle-I, Private Limited, Noida-201301, Vs. D-53, Okhla, Phase-1, Uttar Pradesh. Delhi-110020. Pan-Aafcr6959P (Appellant) (Respondent) Dy. Cit, M/S Rudra Buildwell Projects Central Circle-I, Private Limited, Noida-201301, Vs. D-53, Okhla, Phase-1, Uttar Pradesh. Delhi-110020. Pan-Aaecr9589E (Appellant) (Respondent)

250(4) which was co-equal to that of Assessing Officer and it also took note of fact that notice was Issued to concerned branch of Canara Bank under section 133(6) and it was only after information was received from Canara Bank and material evidence furnished by assessee, that addition was deleted, no interference was called for particularly when

ORIENTAL BANK OF COMMERCE,GURGAON vs. ACIT, SPL. RANGE-07, NEW DELHI

In the result, the appeal filed by the Assessee stands allowed

Bench: Shri Anil Chaturvedi & Shri N.K. Choudhryassessment Year: 2016-17

250 of the Income-tax Act, 1961 (in short ‘the Act’) for the assessment year 2016-17. 2 2. The Assessee has raised following concise grounds of appeal: 1. The Ld. CIT(A) has erred in law and on facts in confirming the disallowance u/s 14A to the extent of Rs. 5.99 crores applying Rule 8D(2)(iii). No expenditure

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

1\n\nAppellant by Shri Pradip Dinodia, CA,\nShri R.K.Kapoor, CA,\nShri Ravi Kumar, CA,\nMs. Shruti Gupta, CA &\nShri Ayush Chaurasia, CA\n\nRespondent by Shri Dharm Veer Singh, CIT DR\nDate of Hearing 24.04.2025\nDate of Pronouncement 30.06.2025\n\nORDER\n\nPER MANISH AGARWAL, AM :\nThese captioned appeals are filed by the Revenue and the\nassessee for various

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

1),\nNew Delhi\nAPPELLANT RESPONDENT\nITA Nos.927 & 2587/Del/2022,\n704/Del/2021, 4328 & 1495/Del/2024\nPage | 2\nAppellant by Shri Pradip Dinodia, CA,\nShri R.K.Kapoor, CA,\nShri Ravi Kumar, CA,\nMs. Shruti Gupta, CA &\nShri Ayush Chaurasia, CA\nRespondent by Shri Dharm Veer Singh, CIT DR\nDate of Hearing 24.04.2025\nDate of Pronouncement 30.06.2025\nORDER\nPER MANISH AGARWAL, AM :\nThese captioned appeals are filed

DCM SHRIRAM LIMITED,DELHI vs. ASSESSMENT UNIT, DELHI

1),\nNew Delhi\nAPPELLANT RESPONDENT \nITA Nos.927 & 2587/Del/2022,\n704/Del/2021, 4328 & 1495/Del/2024\nPage | 2 \nAppellant by Shri Pradip Dinodia, CA,\nShri R.K.Kapoor, CA,\nShri Ravi Kumar, CA,\nMs. Shruti Gupta, CA &\nShri Ayush Chaurasia, CA\nRespondent by Shri Dharm Veer Singh, CIT DR\nDate of Hearing 24.04.2025\nDate of Pronouncement 30.06.2025\nORDER\nPER MANISH AGARWAL, AM :\nThese captioned appeals are filed

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

1\n\nITA Nos.927 & 2587/Del/2022,\n704/Del/2021, 4328 & 1495/Del/2024\n\nAppellant by Shri Pradip Dinodia, CA,\nShri R.K.Kapoor, CA,\nShri Ravi Kumar, CA,\nMs. Shruti Gupta, CA &\nShri Ayush Chaurasia, CA\n\nRespondent by Shri Dharm Veer Singh, CIT DR\nDate of Hearing 24.04.2025\nDate of Pronouncement 30.06.2025\n\nORDER\n\nPER MANISH AGARWAL, AM :\n\nThese captioned appeals are filed

SAMSUNG INDIA ELECTRONICS PVT. LTD.,GURGAON vs. DCIT CIRCLE-22(2), NEW DELHI

In the result, the appeal of the assessee is partly allowed in the aforesaid manner

Bench: Shri G. S. Pannu & Shri Yogesh Kumar U.S.

section 143(2) of the Act and referred the case to the Transfer Pricing Officer (hereinafter referred as “TPO”) u/s. 92CA of the Act for the examination of the arm's length price of its various international transactions. 4. The TPO in her order dated 31.10.2018 passed u/s 92CA(3) of the Act proposed adjustments under the following heads

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)

Transfer Pricing Officer/DCIT-3(3)(2), New Delhi by DCIT Circle-25(1) with the prior approval of Ls. PCIT-9, New Delhi to determine the 'Arms Length Price' under Section 92CA(3) of the Income Tax Act in respect of "International Transactions" entered into by the assessee. 3.2 The Ld. Addl. Commissioner of Income Tax/Transfer Pricing Officer