LI & FUNG INDIA PVT LTD vs. COMMISSIONER OF INCOME TAX

The appeal is allowed and the order dated 25/11/11 of the ITAT Tribunal, Delhi Branch

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

Section 260A of the Income Tax Act, 1961 (hereafter „the IT Act‟) impugns the order dated 30.09.2011 of the Income Tax Appellate Tribunal, Delhi Branch „D‟, New Delhi (hereafter „the Tribunal‟) in ITA No. 5156/Del/2010, for the assessment year 2006-07. The present appeal concerns the alleged apportioning of consideration between the Appellant (i.e. the assessee, M/s Li Fung (India

AMADEUS INDIA PVT. LTD.,NEW DELHI vs. ACIT, CIRCLE- 2(2), NEW DELHI

In the result, appeal of the assessee in ITA No

Bench: Shri N.K. Billaiya & Ms. Suchitra Kamble[A.Y 2014-15]

Section 260A of the Income Tax Act, 1961 (‘Act’) against the order dated 21st August, 2016 passed by the Income Tax Appellate Tribunal (‘ITAT’) in ITA No. 1804/Del/2014 for the Assessment Year (‘AY’) 2009-10. 3. The first issue concerns the deletion of the transfer pricing

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

The appeals are allowed in the above terms, but with no orders as to costs

Section 260A of the Income Tax Act, 1961 (‘Act’). ITA 2015:DHC:10110-DB ITA Nos.110/2014 & 710/2015 Page 2 of 45 No.110 of 2014 is directed against an order dated 2nd August 2013 passed by the Income Tax Appellate Tribunal (‘ITAT’) in ITA No.5237/Del/2010 for the Assessment Year (‘AY’) 2005-06. ITA No.710 of 2015 is an appeal against

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

The appeals are allowed in the above terms, but with no orders as to costs

Section 260A of the Income Tax Act, 1961 (‘Act’). ITA 2015:DHC:10110-DB ITA Nos.110/2014 & 710/2015 Page 2 of 45 No.110 of 2014 is directed against an order dated 2nd August 2013 passed by the Income Tax Appellate Tribunal (‘ITAT’) in ITA No.5237/Del/2010 for the Assessment Year (‘AY’) 2005-06. ITA No.710 of 2015 is an appeal against

AMADEUS INDIA PVT. LTD.,NEW DELHI vs. ACIT, CIRCLE 2(2), NEW DELHI

In the result, the appeal of assessee are allowed

Bench: Sh. Anil Chaturvedi & Sh. Amit Shukla(Through Video Conferencing) Amadeus India Pvt. Ltd., Vs. Acit E-9, Connaught Hose, Circle – 2(2), Connaught Place, New Delhi New Delhi - 110001 Pan No. Aaaca 0364 L (Appellant) (Respondent) Assessee By Shri Taran Deep Singh, Adv. Revenue By Shri Surender Pal, Cit-D.R. Date Of Hearing: 18/05/2021 Date Of Pronouncement: 31/05/2021 Order Per Anil Chaturvedi, Am: This Appeal Filed By The Assessee Is Directed Against The Order Dated 19.09.2019 Of The Asst. Commissioner Of Income Tax, Circle-2(2), Delhi Under Section 143(3) R.W.S 144C(13) Of The Act Pursuant To The Direction Of Dispute Resolution Panel (Drp) – 1, Delhi For Assessment Year 2015-16. 2. The Relevant Facts As Culled From The Material On Records Are As Under :

Section 260A of the Income Tax Act, 1961 (‘Act’) against the order dated 21st August, 2016 passed by the Income Tax Appellate Tribunal (‘ITAT’) in ITA No. 1804/Del/2014 for the Assessment Year (‘AY’) 2009-10. 3. The first issue concerns the deletion of the transfer pricing

M/S. SIS LIVE,GURGAON vs. ACIT, NEW DELHI

In the result the ground No

Bench: I.C.Sudhir & Shri Prashant Maharishisis Live Acit, C/O. Srbc & Associates Llp, Central Circle-17, Room No. Vs. Golf View Corporate Tower B, 356, E-2, Sector-42, Sector Road, Gurgaon Pan:Abrfs4787L (Appellant) (Respondent)

260A of the Income Tax Act contending that the issue concerning the transfer pricing adjustment was not adjudicated by the ITAT in the impugned order on the ground that no addition has been made in the assessment order on account of transfer pricing adjustment in computing the total income of the assessee. Admittedly no addition was made on transfer pricing

COMMISSIONER OF INCOME TAX-I vs. COTTON NATURALS (I) PVT LTD

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

Section 260A of the Income Tax Act, 1961 (Act, for short) relates to determination of arm‘s length rate of interest, paid to the assessed, i.e. Cotton Naturals (I) Pvt. Ltd., by their subsidiary M/s JPC Equestrian, a company registered in the United States of America. The appeal emanates from the order of the Income Tax Appellate Tribunal (Tribunal

COMMISSIONER OF INCOME TAX vs. BENETTON INDIA PVT. LTD.

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

260A of the Income Tax Act, 1961 (hereafter the Act) impugning the orders passed by the Income Tax Appellate Tribunal (hereafter ITAT) in respect of the assessment years (AYs) 2007-08, 2008-09 and 2009-10. 2. The learned ITAT had rejected the Revenue’s appeal (ITA No.457/Del/2013) in respect of the AY 2007-08 as well as the Revenue

M/S PEPSICO INDIA HOLDINGS PVT. LTD.,,GURGAON vs. ACIT,, NEW DELHI

In the result, all the appeals of the assessee are treated as partly allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishi

Section 92B (1). 54. Here, in this case, it has been vehemently argued from the side of the assessee that assessee-company had incurred expenditure on AMP to cater to the needs of the customers in the local market and such an expenditure was neither incurred at the instance or behest of overseas AE nor there was any mutual understanding

PEPSICO INDIA HOLDINGS PVT. LTD.,GURGAON vs. ACIT, CENTRAL CIRCLE- 7, NEW DELHI

In the result, all the appeals of the assessee are treated as partly allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishi

Section 92B (1). 54. Here, in this case, it has been vehemently argued from the side of the assessee that assessee-company had incurred expenditure on AMP to cater to the needs of the customers in the local market and such an expenditure was neither incurred at the instance or behest of overseas AE nor there was any mutual understanding

PEPSI FOODS PVT. LTD.,GURGAON vs. DCIT, NEW DELHI

In the result, all the appeals of the assessee are treated as partly allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishi

Section 92B (1). 54. Here, in this case, it has been vehemently argued from the side of the assessee that assessee-company had incurred expenditure on AMP to cater to the needs of the customers in the local market and such an expenditure was neither incurred at the instance or behest of overseas AE nor there was any mutual understanding

M/S PEPSICO INDIA HOLDINGS PVT. LTD.,,GURGAON vs. ACIT,, NEW DELHI

In the result, all the appeals of the assessee are treated as partly allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishi

Section 92B (1). 54. Here, in this case, it has been vehemently argued from the side of the assessee that assessee-company had incurred expenditure on AMP to cater to the needs of the customers in the local market and such an expenditure was neither incurred at the instance or behest of overseas AE nor there was any mutual understanding

M/S PEPSICO INDIA HOLDINGS PVT. LTD.,,GURGAON vs. ACIT,, NEW DELHI

In the result, all the appeals of the assessee are treated as partly allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishi

Section 92B (1). 54. Here, in this case, it has been vehemently argued from the side of the assessee that assessee-company had incurred expenditure on AMP to cater to the needs of the customers in the local market and such an expenditure was neither incurred at the instance or behest of overseas AE nor there was any mutual understanding

M/S. PEPSI FOODS LIMITED,GURGAON vs. ACIT, NEW DELHI

In the result, all the appeals of the assessee are treated as partly allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishi

Section 92B (1). 54. Here, in this case, it has been vehemently argued from the side of the assessee that assessee-company had incurred expenditure on AMP to cater to the needs of the customers in the local market and such an expenditure was neither incurred at the instance or behest of overseas AE nor there was any mutual understanding

BAUSCH & LOMB EYECARE (INDIA) PVT. LTD.

The appeals of the Assessee are allowed and the appeals of the Revenue

260A of the Income Tax Act, 1961 (‘Act’). The Assessment Years (‘AYs’) involved are 2006-07 to 2010-11. 2. The Assessee’s appeals, ITA Nos. 643 of 2014, 675 of 2014, 676 of 2014 and 677 of 2014, are directed against the common order dated 23rd May 2014 passed by the Income Tax Appellate Tribunal (‘ITAT

BAUSCH & LOMB EYECARE (INDIA) PVT. LTD.

The appeals of the Assessee are allowed and the appeals of the Revenue

260A of the Income Tax Act, 1961 (‘Act’). The Assessment Years (‘AYs’) involved are 2006-07 to 2010-11. 2. The Assessee’s appeals, ITA Nos. 643 of 2014, 675 of 2014, 676 of 2014 and 677 of 2014, are directed against the common order dated 23rd May 2014 passed by the Income Tax Appellate Tribunal (‘ITAT

BAUSCH & LOMB EYECARE (INDIA) PVT. LTD.

The appeals of the Assessee are allowed and the appeals of the Revenue

260A of the Income Tax Act, 1961 (‘Act’). The Assessment Years (‘AYs’) involved are 2006-07 to 2010-11. 2. The Assessee’s appeals, ITA Nos. 643 of 2014, 675 of 2014, 676 of 2014 and 677 of 2014, are directed against the common order dated 23rd May 2014 passed by the Income Tax Appellate Tribunal (‘ITAT

BAUSCH & LOMB EYECARE (INDIA) PVT. LTD.

The appeals of the Assessee are allowed and the appeals of the Revenue

260A of the Income Tax Act, 1961 (‘Act’). The Assessment Years (‘AYs’) involved are 2006-07 to 2010-11. 2. The Assessee’s appeals, ITA Nos. 643 of 2014, 675 of 2014, 676 of 2014 and 677 of 2014, are directed against the common order dated 23rd May 2014 passed by the Income Tax Appellate Tribunal (‘ITAT