HERO FINCORP LIMITED,NEW DELHI vs. ACIT, CIRCLE 11(1), DELHI, C.R. BUILDING

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

section 56(2)(viib). It is evidenced, during the appellate proceedings, by the\nfact that M/s. Otter Ltd has immediately sold certain no of shares to an India\nbased Indian resident entity. M/s. Link Investment Trust. It is clearly evident\nthat if M/s. Link Investment Trust had bought the shares of the appellant-\ncompany at such a huge premium

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

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

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

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

section 92C (2) of the Act.\n11. That on facts and circumstances of the case and in law, the CIT(A)\nhave erred in not directing the AO/TPO to use multiple years data for\ncomparable companies as advocated by the provisions of Rule 10B(4) of\nthe Rules for the purposes of determination of arm's length price.\nCORPORATE

TEVA PHARMACEUTICAL & CHEMICAL INDUSTRIES INDIA PRIVATE LIMITED,MUMBAI vs. DCIT, CIRCLE-25(1), DELHI

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalteva Pharmaceutical & Chemical Vs Assessment Unit, Income Industries India Private Limited, Tax Department/Deputy 8Th Floor, C-Wing Time Square, Commissioner Of Income Andherikurla Road, Marol Naka, Tax, Circle 25(1), Opp Mittal Industrial Estate C. R. Building, Delhi- Andheri (E), Mumbai 400059, 110001 Maharashtra, India Pan: Bnspk7225H Appellant Respondent Assessee By Sh. Sachit Jolly, Sr. Adv, Sh. Sohamdua, Adv& Sh. Abhiudaya Shankar Bajpai, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 19/01/2026 Date Of Pronouncement 19/01/2026 Order Per Yogesh Kumar, U.S. Jm: The Captioned Appeal Is Filed By The Assessee Challenging The Final Assessment Order Passed U/S 143(3) R.W.S. 144C(13) R.W.

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

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

COIM INDIA PRIVATE LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 4(2) , DELHI

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalcoim India Private Limited Vs Deputy Commissioner Of Shop No. 4, Ground Floor Income Tax, Income Tax Rajendrabhawan, Patel Nagar, Department, Circle 4(2), East Central Delhi, Delhi Delhi Pan: Aabcy0901A Appellant Respondent Assessee By Sh. Nikhil Aggarwal, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 21/01/2026 Date Of Pronouncement 23/01/2026

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

SIGNIFY INNOVATIONS INDIA LIMITED,HARYANA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3(1), HARYANA

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalsignify Innovations India Limited Vs Deputy Commissioner Of 9B, 9Th Floor, Dlf Cyber City, Income Tax, Circle 3(1), Range Dlf Qe, S.O. Gurgaon, Haryana Code 107, Income Tax Officer, Pan: Aaicp0987G Shankar Chowk, Phase V, Udyogvihar, Sector 19, Gurugram, Haryana Appellant Respondent Assessee By Ms. Reema Grewal, Ca Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 20/01/2026 Date Of Pronouncement 23/01/2026

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

DNATA INTERNATIONAL PRIVATE LIMITED,HARYANA vs. DCIT, CIRCLE 1(1), GURGAON OR ASSESSMENT UNIT, INCOME TAX DEPARTMENT, GURGAON

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwaldnata International Private Vs Deputy Commissioner Of Limited. Ground Floor, R1, R2, Income Tax, Circle 1(1), Park Centra, Sector-30, Nh-8, Gurgaon Or Assessment Unit, Gurgaon, Haryana Income Tax Department, Pan: Aadcd7460P Gurgaon, Haryana Appellant Respondent Assessee By Sh. Nikhil Tiwari, Adv (Virtual) Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 20/01/2026 Date Of Pronouncement 23/01/2026

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

FMI AUTOMOTIVE COMPONENTS PRIVATE LIMITED,MANESAR vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT (JAO- DCIT/ACIT, CIRCLE 7(1), NEW DELHI

In the result, appeals of the Assessee are allowed

253 or in clause (c)\nof 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 the\ncase may be, referred to in sub-section (1) is not in conformity with the\nfinal decision on the question

DCIT, NEW DELHI vs. M/S. NEWBURY HOLDING TWO LTD., NEW DELHI

In the result, the Cross Objections of the assessees are\nallowed and consequently the appeals of the revenue are liable\nto be dismissed

253 so as to include an order of\nassessment passed under sub-section (3) of section 143 or under\nsection 147 in pursuance of the directions of the \"Dispute\nResolution Panel” as an appealable order.\n45.4 It would be the choice of the assessee whether to file an objection\nagainst the draft assessment order before the Dispute Resolution Panel

HONDA TRADING ASIA COMPANY LIMITED,THAILAND vs. DCIT, INT. TAXATION, NOIDA

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 29[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

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

2) by the eligible assessee. 2020:DHC:3740-DB ITA 77/2019 Page 13 of 18 (14A) The provisions of this section shall not apply to any assessment or reassessment order passed by the Assessing Officer with the prior approval of the [Principal Commissioner or] Commissioner as provided in sub-section (12) of section 144BA.] (15) For the purposes of this

AL MAHA FOODS INTERNATIONAL PRIVATE LIMITED,NEW DELHI vs. NATIONAL FACELESS ASSESSMENT CENTRE (JAO - DCIT CIRCLE 1(1), DELHI), NEW DELHI

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalal Maha Foods International Vs National Faceless Private Limited, 1122, Dlf Assessment Centre (Jao- Tower A, Jasola, New Friends Dcit Circle 1(1), C. R. Colony, S.O. Zakir Nagar, Building, I. P. Estate, Delhi Delhi-110025 New Delhi Pan: Aabca8743L Appellant Respondent Assessee By Sh. Salil Kapoor, Adv& Ms. Ananya Kapoor, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 19/01/2026 Date Of Pronouncement 21/01/2026

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

AIRBNB PAYMENTS INDIA PRIVATE LIMITED,GURUGRAM, HARYANA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1), GURUGRAM, HARYANA, GURUGRAM, HARYANA

In the result, the appeal of the Assessee is allowed

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalairbnb Payments India Private Dcit, Circle-1(1), Limited, Gurugram, Haryana. Level 9, Spaze I Tech Park, Vs A1 Tower, Sector-49, . Sohna Road, Gurugram-122018 Haryana. Pan-Aanca6203B (Appellant) (Respondent) Assessee By Ms. Reema Grewal, Ca Department By Shri S.K. Jadhav, Cit-Dr Date Of Hearing 20/01/2026 Date Of Pronouncement 23/01/2026 O R D E R Per Manish Agarwal, Am: The Present Appeal Is Filed By The Assessee Against The Final Assessment Order Passed By Ao Dated 18.07.2024 U/S 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income Tax Act, 1961 (“The Act” In Short) For Assessment Year 2020-21 Subsequent To The Direction Of The Ld. Dispute Resolution Panel (Drp) Vide Direction Dated 24.06.2024. 2. The Assessee Raised Ground No. 2 Contending That The Final Assessment Order Dated 18/07/2024 Passed By The A.O. Is Time Barred By Limitation & Is Bad In Law, As It Has Been Passed Beyond The Time Frame Prescribed Under Section 153(1) Read With Section 153(4) Of The Income Tax Act, 1961 ('Act' For Short). The Ld. Assessee’S Representative Relying On Airbnb Payments India Private Limited Vs. Dcit The Ratio Laid Down By The Hon'Ble High Court Of Madras In The Case Of Commissioner Of Income-Tax Vs. Roca Bathroom Products (P.) Ltd. [2022] 445 Itr 537 (Madras) & Also Plethora Of Orders Passed By The Co-Ordinate Bench Of The Tribunal, Hyderabad Bench Sought For Allowing The Ground No. 2 Of The Assessee.

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

AIRBNB INDIA PRIVATE LIMITED,DELHI, INDIA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1), CENTRAL REVENUE BUILDING, DELHI, DELHI, INDIA

In the result, the appeal of the Assessee is allowed

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalairbnb India Private Limited, Dcit, Circle-1(1), 5Th Floor, Caddie Commercial Central Revenue Building, Tower, Aerocity, Vs. Delhi. New Delhi-110037. Pan-Aakca5525B (Appellant) (Respondent) Assessee By Ms. Reema Grewal, Ca Department By Shri S.K. Jadhav, Cit-Dr Date Of Hearing 20/01/2026 Date Of Pronouncement 23/01/2026 O R D E R Per Manish Agarwal, Am: The Present Appeal Is Filed By The Assessee Against The Final Assessment Order Passed By Ao Dated 24.07.2024 U/S 143(3) R.W.S. 144C(13) R.W.S. & 144B Of The Income Tax Act, 1961 (“The Act” In Short) For Assessment Year 2020-21 Subsequent To The Direction Of The Ld. Dispute Resolution Panel (Drp) Vide Direction Dated 27.06.2024. 2. The Assessee Raised Ground No. 2 Contending That The Final Assessment Order Dated 24/07/2024 Passed By The A.O. Is Time Barred By Limitation & Is Bad In Law, As It Has Been Passed Beyond The Time Frame Prescribed Under Section 153(1) Read With Section 153(4) Of The Income Tax Act, 1961 ('Act' For Short). The Ld. Assessee’S Representative Relying On The Ratio Laid Down By The Hon'Ble High Court Of Madras In The Case Of Commissioner Of Income-Tax Vs. Roca Bathroom Products (P.) Ltd. [2022] 445 537 (Madras) & Also Airbnb India Pvt. Ltd. Vs. Ito Plethora Of Orders Passed By The Co-Ordinate Bench Of The Tribunal, Hyderabad Bench Sought For Allowing The Ground No. 2 Of The Assessee.

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

HASKONINGDHV CONSULTING PRIVATE LIMITED,NEW DELHI vs. ACIT, CIRCLE 10(1), NEW DELHI

In the result, appeal of the Assessee is allowed

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalhaskoningdhv Consulting Vs The Assistant Commissioner Private Limited, Office No. 204, Of Income Tax, Circle 10(1), 2Nd Floor, Rs Tower, Plot No. B C. R. Building, New Delhi 358A, New No. 1267, New Ashok Nagar, Vasundhara Enclave, East Delhi Pan: Aaacm8966G Appellant Respondent Assessee By Sh. Harpreet Singh Ajmani, Adv Revenue By Sh. S. K. Jadhav, Cit Dr Date Of Hearing 21/01/2026 Date Of Pronouncement 23/01/2026

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