DELPHI AUTOMOTIVE SYSTEMS (P) LTD,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME-TAX, NEW DELHI
In the result, the appeal of the assessee is partly allowed for statistical purposes
ITA 1361/DEL/2015[2010-11]Status: DisposedITAT Delhi09 Oct 2023AY 2010-11
Bench: Shri M. Balaganesh & Shri Anubhav Sharmaaptive Components India P. Ltd, Vs. Deputy Commissioner (Formerly Known As Delphi Of Income-Tax, Automotive Systems P. Ltd), Circle-7(1), P-24, Green Park Extension, New Delhi South Delhi, New Delhi-110016 (Appellant) (Respondent) Pan:Aaacd0226E
For Appellant: Sh. Neeraj Jain, AdvFor Respondent: Sh. Rajesh Kumar, CIT DR
Section 143(3)Section 144CSection 92CSection 92C(2)
transfer pricing documentation maintained by the assessee, the transactions of purchase of tools was benchmarked applying TNMM method, by using combined transaction approach since the transaction was found to be inextricably linked to the manufacturing operations of Delphi India. The assessee had imported these tools from its AEs and sold to Tata Motors Ltd. It was pleaded by the assessee
