DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (j) any foreign company. 45.3 Further, consequential amendments have been made – (i) in sub-section (1) of section 131 so as to provide that the “Dispute Resolution Panel” shall have the same powers as are vested in a Court under the Code of Civil Procedure

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (j) any foreign company. 45.3 Further, consequential amendments have been made – (i) in sub-section (1) of section 131 so as to provide that the “Dispute Resolution Panel” shall have the same powers as are vested in a Court under the Code of Civil Procedure

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (j) any foreign company. 45.3 Further, consequential amendments have been made – (i) in sub-section (1) of section 131 so as to provide that the “Dispute Resolution Panel” shall have the same powers as are vested in a Court under the Code of Civil Procedure

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (j) any foreign company. 45.3 Further, consequential amendments have been made – (i) in sub-section (1) of section 131 so as to provide that the “Dispute Resolution Panel” shall have the same powers as are vested in a Court under the Code of Civil Procedure

DCIT, NEW DELHI vs. M/S WICKWOOD DEVELOPMENT LTD.,, NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (j) any foreign company. 45.3 Further, consequential amendments have been made – (i) in sub-section (1) of section 131 so as to provide that the “Dispute Resolution Panel” shall have the same powers as are vested in a Court under the Code of Civil Procedure

DCIT, NEW DELHI vs. ISERVICES INVESTMENTS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (j) any foreign company. 45.3 Further, consequential amendments have been made – (i) in sub-section (1) of section 131 so as to provide that the “Dispute Resolution Panel” shall have the same powers as are vested in a Court under the Code of Civil Procedure

THE PR. COMMISSIONER OF INCOME TAX -4 vs. HEADSTRONG SERVICES INDIA PVT. LTD.

d) report, if any, of the Assessing Officer, Valuation Officer or Transfer Pricing Officer or any other authority; (e) records relating to the draft order; (f) evidence collected by, or caused to be collected by, it; and (g) result of any enquiry made by, or caused to be made by, it. (7) The Dispute Resolution Panel may, before issuing

WIN MEDICARE PRIVATE LIMITED,DELHI vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT (DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 25(1), DELHI), DELHI

In the result, appeal of the Assessee is allowed

253 or in clause (c)\nof sub-section (2) of section 260A.\n(4) Where the order of 22[the Joint Commissioner (Appeals) or] the\nCommissioner (Appeals) or the order of the Appellate Tribunal, as the\ncase may be, referred to in sub-section (1) is not in conformity with the\nfinal decision on the question

BAXTER INDIA PRIVATE LIMITED,GURGAON, HARYANA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, NEW DELHI

In the result, appeals of the Assessee are allowed

253 or in clause\n(c) of sub-section (2) of section 260A.\n(4) Where the order of 29[the Joint Commissioner (Appeals) or] the\nCommissioner (Appeals) or the order of the Appellate Tribunal, as\nthe case may be, referred to in sub-section (1) is not in conformity\nwith the final decision on the question

CLAAS AGRICULTURAL MACHINERY PRIVATE LIMITED,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 4(2), NEW DELHI, NEW DELHI

In the result, appeal of the Assessee is allowed

253 or in clause (c)\nof sub-section (2) of section 260A.\n(4) Where the order of 22[the Joint Commissioner (Appeals) or] the\nCommissioner (Appeals) or the order of the Appellate Tribunal, as the\ncase may be, referred to in sub-section (1) is not in conformity with the\nfinal decision on the question

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)

section 92C (2) of the Act. 11. That on facts and circumstances of the case and in law, the CIT(A) have erred in not directing the AO/TPO to use multiple years data for comparable companies as advocated by the provisions of Rule 10B(4) of the Rules for the purposes of determination of arm's length price. CORPORATE

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)

section 92C (2) of the Act. 11. That on facts and circumstances of the case and in law, the CIT(A) have erred in not directing the AO/TPO to use multiple years data for comparable companies as advocated by the provisions of Rule 10B(4) of the Rules for the purposes of determination of arm's length price. CORPORATE

MSD PHARMACEUTICALS PRIVATE LIMITED,NEW DELHI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 16(1), NEW DELHI

In the result, appeals of the Assessee are allowed

253 or in clause\n(c) of sub-section (2) of section 260A.\n(4) Where the order of 29[the Joint Commissioner (Appeals) or] the\nCommissioner (Appeals) or the order of the Appellate Tribunal, as\nthe case may be, referred to in sub-section (1) is not in conformity\nwith the final decision on the question

VIVO MOBILE INDIA PRIVATE LIMITED,GURGAON vs. ACIT, CIRCLE-25(1), DELHI

In the result, appeals of the Assessee are allowed

253 or in clause\n(c) of sub-section (2) of section 260A.\n(4) Where the order of 29[the Joint Commissioner (Appeals) or]\nthe\nCommissioner (Appeals) or the order of the Appellate Tribunal, as\nthe case may be, referred to in sub-section (1) is not in conformity\nwith the final decision on the question

EVERSUB INDIA PRIVATE LIMITED ,HARYANA vs. DCIT CIRCLE-22(2), DELHI

In the result, appeals of the Assessee are allowed

253 or in clause\n(c) of sub-section (2) of section 260A.\n(4) Where the order of 29[the Joint Commissioner (Appeals) or] the\nCommissioner (Appeals) or the order of the Appellate Tribunal, as\nthe case may be, referred to in sub-section (1) is not in conformity\nwith the final decision on the question

MSD PHARMACEUTICALS PRIVATE LIMITED,NEW DELHI vs. DCIT, CIRCLE-16(1), DELHI

In the result, appeals of the Assessee are allowed

253 or in clause\n(c) of sub-section (2) of section 260A.\n(4) Where the order of 29[the Joint Commissioner (Appeals) or] the\nCommissioner (Appeals) or the order of the Appellate Tribunal, as\nthe case may be, referred to in sub-section (1) is not in conformity\nwith the final decision on the question

VODAFONE IDEA LTD. (EARLIER KNWON AS VODAFONE MOBILE SERVICES LTD.),MUMBAI vs. ACIT,. CIRCLE-26(2), NEW DELHI

In the result, all above said grounds are allowed for statistical purpose

Bench: Shri S. Rifaur Rahman & Shriyogesh Kumar U.S.Vodafone Idea Ltd Vs. Acit, (Earlier Known As Vodafone Circle-26(2), Mobile Services Ltd) New Delhi 10Th Floor, Birla Centurion, Century Mills Compound, Pandurang Budhkar Marg, Worli, Mumbai, Maharastra (Appellant) (Respondent) Pan: Aaacb2100P

pricing adjustment made in the sum of Rs 1,20,54,020/- in respect of international transaction towards payment of royalty. 5. Ground No. 3 to 3.3 raised by the assessee is about Disallowanceofdepreciation amounting to Rs. 12,47,17,47,967/- in respect of right to use 3G Spectrum. 5.1 Considered the rival submissions and material placed onrecord. Brief

UCWEB MOBILE PRIVATE LIMITED,GURGAON vs. ASSESSMENT UNIT, INOCOME TAX DEPARTMENT, GURGAON

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

Bench: SHRI MAHAVIR SINGH (Vice President), SHRI MANISH AGARWAL (Accountant Member)

253(1)(d) of the Income-tax Act, 1961 ("the Act") against final assessment order dated 27.06.2024 ("Impugned Order") issued under Section 43(3) read with Section 144C(13) of the Act, by Assessment Unit, Income Tax Department ("AO") in pursuance of the Directions dated 29.05.2024 issued under Section 144C(5) by the Ld. Dispute Resolution Panel-1, New Delhi