RANBAXY LABORATORIES LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, we direct the AO to reduce the book profit u/s 115JB of the Act by the amount of reversal of the provision of Rs

Bench: Sh. I. C.Sudhir Judicialmember & Sh. Prashant Maharishia.Y.: - 2008-09 Ranbaxy Laboratories Ltd. Vs Acit 12Th Floor, Devika Tower, Range -15 6, Nehru Place New Delhi New Delhi Pan No. Aaacr0127N (Appellant) (Respondent)

Section (2) to Section 14A of the Act and sub Rule (1) to Rule 8D of the Rules. 14. The view and legal ratio expressed above is not being elucidated for the first time. The Delhi High Court in Maxopp Investment Ltd. v. CIT [2012] 347 ITR 272/203 Taxman 364/15 taxmann.com 390 has observed:- 'Scope of sub-sections

M/S. HONDA SIEL POWER PRODUCTS LTD.,GAUTAM BUDH NAGAR vs. DCIT, NEW DELHI

In the result, both the appeals of the assessee-company are partly allowed for statistical purposes

Bench: : Shri I.C. Sudhir & Shri L.P. Sahu

section 40(a)(i) are directed to be deleted. Accordingly, these grounds of appeal stand allowed. In view of this decision of co-ordinate Bench in the case of assessee, the advance ruling relied on by the ld. DR does not help the revenue, as the said ruling is binding on that applicant and not upon the Tribunal u/s. 245S

THE COMMISSIONER OF INCOME TAX-III vs. SHRI VARDHMAN OVERSEAS LTD.

Bench: HON'BLE MR. JUSTICE SANJIV KHANNA,HON'BLE MR. JUSTICE R.V.EASWAR

price in computing the business income of the assessee. The second question is whether by not paying them for a period of four years and above the assessee had obtained some benefit in respect of the trading liability allowed in the earlier years. The argument of the learned standing counsel that the non- payment or non-discharge of the liability

THE COMMISSIONER OF INCOME TAX-III vs. SHRI VARDHMAN OVERSEAS LTD.

price in computing the business income of the assessee. The second question is whether by not paying them for a period of four years and above the assessee had obtained some benefit in respect of the trading liability allowed in the earlier years. The argument of the learned standing counsel that the non- payment or non-discharge of the liability

THE COMMISSIONER OF INCOME TAX-III vs. SHRI VARDHMAN OVERSEAS LTD.

price in computing the business income of the assessee. The second question is whether by not paying them for a period of four years and above the assessee had obtained some benefit in respect of the trading liability allowed in the earlier years. The argument of the learned standing counsel that the non- payment or non-discharge of the liability

STERIA INDIA LTD.,NOIDA vs. ADDL.CIT, SPECIAQL RANGE-8, NEW DELHI

In the result ITA number 5745/del/2018 for assessment year 2014 – 15

Bench: Shri Kuldip Singh & Shri Prashant Maharishi

Section 144C of the income tax act 1961 on 5 December 2016 determining total income of the assessee at ₹ 1,515,053,703/– against which this assessee has preferred the appeal before us. 18. Coming to ground number 2 of the appeal of the assessee, the learned authorised representative contested the comparable ( 1) Infosys BPO Ltd and submitted that

M/S STERIA NDIA LTD.,,NOIDA vs. ADDL CIT, NEW DELHI

In the result ITA number 5745/del/2018 for assessment year 2014 – 15

Bench: Shri Kuldip Singh & Shri Prashant Maharishi

Section 144C of the income tax act 1961 on 5 December 2016 determining total income of the assessee at ₹ 1,515,053,703/– against which this assessee has preferred the appeal before us. 18. Coming to ground number 2 of the appeal of the assessee, the learned authorised representative contested the comparable ( 1) Infosys BPO Ltd and submitted that

STERIA (INDIA) LTD.,NOIDA vs. ADDL. CIT, SPL. RANGE- 8 , NEW DELHI

In the result ITA number 5745/del/2018 for assessment year 2014 – 15

Bench: Shri Kuldip Singh & Shri Prashant Maharishi

Section 144C of the income tax act 1961 on 5 December 2016 determining total income of the assessee at ₹ 1,515,053,703/– against which this assessee has preferred the appeal before us. 18. Coming to ground number 2 of the appeal of the assessee, the learned authorised representative contested the comparable ( 1) Infosys BPO Ltd and submitted that

M/S. DHARAMPAL SATYAPAL LTD.,DELHI vs. ACIT, NEW DELHI

Bench: Shri Amit Shukla & Sh. Prashant Maharishi(Through Video Conferencing) Assessment Year: 2012-13 M/S. Dharampal Satyapal Ltd. Acit, 1711, S. P. Mukherjee Marg, Vs Central Circle – 29, Delhi-110006 New Delhi Pan No. Aaacd0132H (Appellant) (Respondent) Appellant By Sh. R. S. Singhavi, Ca Sh. Satyajeet Goel, Ca Respondent By Sh. Sanjay I. Bara, Cit Dr Date Of Hearing: 28/08/2020 Date Of Pronouncement: 07/10/2020 Order

Transfer Pricing TPO : Adjustment in respect 7,80,19,356/ Page 91-96 loan is required to 15 benchmarking of Page 3-8 Para 4.2 - Para73- 77 benchmarked as per interest received on foreign currency loan LIBOR and TPO was DRP: not justified in Page 56 Para 18.3 applying SBI PLR. The adjustment was accordingly deleted. 7. The learned authorised

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

256/- was made. 11. The assessee carried the matter before the ld. CIT(A) and challenged the validity of the assessment order before the DRP but without any success. 12. It was strongly contended before the DRP that the assessee is not an eligible assessee within the provisions of section 144C of the Act. 13. This plea was dismissed

ADDL. CIT, SPECIAL RANGE- 1 , NEW DELHI vs. ARICENT TECHNOLOGIES (HOLDINGS) LTD., NEW DELHI

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

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

256 allegedly holding that the appellant had received interest under section 244A of the Act on the income tax refund of Rs.24,77,65,100 during the year under consideration. 3.1. That the DRP/ assessing officer erred on facts and in law in not appreciating that the appellant did not receive any interest 40 ITA Nos.1308/Del/2015; 4913 & 5026/Del/2018; 7637/Del/2018

M/S. ARICENT TECHNOLOGIES (HOLDINGS) LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

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

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

256 allegedly holding that the appellant had received interest under section 244A of the Act on the income tax refund of Rs.24,77,65,100 during the year under consideration. 3.1. That the DRP/ assessing officer erred on facts and in law in not appreciating that the appellant did not receive any interest 40 ITA Nos.1308/Del/2015; 4913 & 5026/Del/2018; 7637/Del/2018

ARIVENT TECHNOLOGIES HOLDINGS LTD.,NEW DELHI vs. DCIT, NEW DELHI

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

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

256 allegedly holding that the appellant had received interest under section 244A of the Act on the income tax refund of Rs.24,77,65,100 during the year under consideration. 3.1. That the DRP/ assessing officer erred on facts and in law in not appreciating that the appellant did not receive any interest 40 ITA Nos.1308/Del/2015; 4913 & 5026/Del/2018; 7637/Del/2018

ARICENT TECHNOLOGIES (HOLDINGS) LTD.,NEW DELHI vs. JCIT, SPECIAL RANGE- 1 , NEW DELHI

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

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

256 allegedly holding that the appellant had received interest under section 244A of the Act on the income tax refund of Rs.24,77,65,100 during the year under consideration. 3.1. That the DRP/ assessing officer erred on facts and in law in not appreciating that the appellant did not receive any interest 40 ITA Nos.1308/Del/2015; 4913 & 5026/Del/2018; 7637/Del/2018

ARICENT TECHNOLOGIES (HOLDINGS) LTD.,NEW DELHI vs. ADDL. CIT, SPECIAL RANGE- 1 , NEW DELHI

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

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

256 allegedly holding that the appellant had received interest under section 244A of the Act on the income tax refund of Rs.24,77,65,100 during the year under consideration. 3.1. That the DRP/ assessing officer erred on facts and in law in not appreciating that the appellant did not receive any interest 40 ITA Nos.1308/Del/2015; 4913 & 5026/Del/2018; 7637/Del/2018

ARICENT TECHNOLOGIES (HOLDINGS) LTD.,NEW DELHI vs. DCIT, CIRCLE- 3(1), NEW DELHI

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

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

256 allegedly holding that the appellant had received interest under section 244A of the Act on the income tax refund of Rs.24,77,65,100 during the year under consideration. 3.1. That the DRP/ assessing officer erred on facts and in law in not appreciating that the appellant did not receive any interest 40 ITA Nos.1308/Del/2015; 4913 & 5026/Del/2018; 7637/Del/2018

ETT LTD (FORMERLY KNOWN AS INDIAN EXPRESS MULTIMEDIA LTD),NEW DELHI vs. CIT, CENTRAL-II, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Sh. Amit Shukla & Sh. Anadee Nath Misshraassessment Year: 2013-14

1,61,37,41,713/ 161,36,85,293/ 161,36,293/- U/s 143 (3) dated 10.08.15 8. After referring to the aforesaid history, he submitted that in all the assessment years, the assessee’s claim for deduction u/s 80 IA has been scrutinized after due verification and have been allowed by the respective Assessing Officers and all the said

LG ELECTRONICS INC., KOREA (LGEK),NOIDA vs. DCIT, CIRCLE- 2(2)(1), INTERNATIONAL TAXATION , NEW DELHI

In the result all the 9 appeals filed by the assessee are allowed with above direction for statistical purposes

Bench: Smt Diva Singh & Shri Prashant Maharishi

section 9(1)(i) as also a fixed place PE in India in terms of Article 5(1) and 5(2) of the Indo-South Korea Double Tax Avoidance Agreement (“DTAA”). In coming to the aforesaid conclusion, the assessing officer has held that LG Electronics India Ltd. (“LGEIL”), the Indian subsidiary, was legal and economically dependent on the Appellant