LG ELECTRONICS INDIA PVT. LTD.,NEW DELHI vs. ADDL. CIT, SPECIAL RANGE- 5, NEW DELHI

In the result, the appeal of the revenue in ITA No

Bench: Shri Mahavir Singh & Shri M. Balaganesh

transfer pricing adjustment of Rs. 809,06,65,961/- on account of alleged brand building activity undertaken by the assessee for the AE as under:- Computation of TP adjustment Rs. Value of sales 1,25,64,10,00,000 AMP/Sales of the comparables 3.69% Amount that represents bright line 4,636,152,900 Expenditure on AMP by assessee

DCIT, NOIDA vs. M/S. L.G. ELECTRONICS INDIA PVT. LTD., GREATER NOIDA

In the result, the appeal of the revenue in ITA No

Bench: Shri Mahavir Singh & Shri M. Balaganesh

transfer pricing adjustment of Rs. 809,06,65,961/- on account of alleged brand building activity undertaken by the assessee for the AE as under:- Computation of TP adjustment Rs. Value of sales 1,25,64,10,00,000 AMP/Sales of the comparables 3.69% Amount that represents bright line 4,636,152,900 Expenditure on AMP by assessee

DCIT, CIRCLE-13(1), NEW DELHI vs. LG ELECTRONICS INDIA PVT. LTD., DELHI

In the result, the appeal of the revenue in ITA No

Bench: Shri Mahavir Singh & Shri M. Balaganesh

transfer pricing adjustment of Rs. 809,06,65,961/- on account of alleged brand building activity undertaken by the assessee for the AE as under:- Computation of TP adjustment Rs. Value of sales 1,25,64,10,00,000 AMP/Sales of the comparables 3.69% Amount that represents bright line 4,636,152,900 Expenditure on AMP by assessee

DCIT, CIRCLE-15(2), NEW DELHI vs. LG ELECTRONICS INDIA PVT. LTD., NEW DELHI

In the result, the appeal of the revenue in ITA No

Bench: Shri Mahavir Singh & Shri M. Balaganesh

transfer pricing adjustment of Rs. 809,06,65,961/- on account of alleged brand building activity undertaken by the assessee for the AE as under:- Computation of TP adjustment Rs. Value of sales 1,25,64,10,00,000 AMP/Sales of the comparables 3.69% Amount that represents bright line 4,636,152,900 Expenditure on AMP by assessee

LG ELECTRONICS INDIA PRIVATE LIMITED,MATHURA ROAD, NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

In the result, the appeal of the revenue in ITA No

Bench: Shri Mahavir Singh & Shri M. Balaganesh

transfer pricing adjustment of Rs. 809,06,65,961/- on account of alleged brand building activity undertaken by the assessee for the AE as under:- Computation of TP adjustment Rs. Value of sales 1,25,64,10,00,000 AMP/Sales of the comparables 3.69% Amount that represents bright line 4,636,152,900 Expenditure on AMP by assessee

LG ELECTRONICS INDIA PVT. LTD.,NEW DELHI vs. ADDL. CIT, SPECIAL RANGE- 5, NEW DELHI

In the result, the appeal of the revenue in ITA No

Bench: Shri Mahavir Singh & Shri M. Balaganesh

transfer pricing adjustment of Rs. 809,06,65,961/- on account of alleged brand building activity undertaken by the assessee for the AE as under:- Computation of TP adjustment Rs. Value of sales 1,25,64,10,00,000 AMP/Sales of the comparables 3.69% Amount that represents bright line 4,636,152,900 Expenditure on AMP by assessee

LG ELECTRONICS INDIA PVT. LTD.,NEW DELHI vs. DCIT, CIRCLE-15(2), NEW DELHI

In the result, the appeal of the revenue in ITA No

Bench: Shri Mahavir Singh & Shri M. Balaganesh

transfer pricing adjustment of Rs. 809,06,65,961/- on account of alleged brand building activity undertaken by the assessee for the AE as under:- Computation of TP adjustment Rs. Value of sales 1,25,64,10,00,000 AMP/Sales of the comparables 3.69% Amount that represents bright line 4,636,152,900 Expenditure on AMP by assessee

SRF LIMITED,DELHI vs. ASSISTANT / DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 10(1), NEW DELHI, DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

prices at which power was purchased from respective State Electricity Board. 64. In a case where the assessee operates a Wind Power Mill (WPP) unit at Tamil Nadu to generate electricity primarily for consumption by its manufacturing units. During the year, the assessee had transferred the WPP units at effective rate of Rs. 6.35 p.u, based on fact that Tamil

SRF LIMITED ,DELHI vs. ACIT, CIRCLE-10(1), DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

prices at which power was purchased from respective State Electricity Board. 64. In a case where the assessee operates a Wind Power Mill (WPP) unit at Tamil Nadu to generate electricity primarily for consumption by its manufacturing units. During the year, the assessee had transferred the WPP units at effective rate of Rs. 6.35 p.u, based on fact that Tamil

SRF LIMITED,NEW DELHI vs. ACIT, CIRCLE-10(1), DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

prices at which power was purchased from respective State Electricity Board. 64. In a case where the assessee operates a Wind Power Mill (WPP) unit at Tamil Nadu to generate electricity primarily for consumption by its manufacturing units. During the year, the assessee had transferred the WPP units at effective rate of Rs. 6.35 p.u, based on fact that Tamil

MARUBENI INDIA PVT. LTD

In the result the appeal of the revenue in ITA No

section (3), the TPO ought to have considered the data relating to the earlier two years. It would perhaps have been appropriate for us to consider the submission of the assessee in normal circumstances, but from paragraph 23 of the order of the Tribunal we find that the assessee did not press this point before the Tribunal, leading

MCKINSEY KNOWLEDGE CENTRE INDIA PVT. LTD.,HARYANA vs. DCIT CIRCLE 16(1) , DELHI

In the result, assessee’s appeal is partly allowed for statistical purposes

Bench: Shri Shamim Yahya & Shri Sudhir Kumarmckinsey Knowledge Centre India Pvt. Ltd., Vs. Dcit, Circle 16 (1), 3Rd Floor, Block Iii, Delhi. Vatika Business Park, Sector 49, Sohna Road, Gurgaon – 122 018 (Haryana). (Pan : Aaccm2356G) (Appellant) (Respondent) Assessee By : Shri Porus Kaka, Sr. Advocate Shri Divesh Chawla, Advocate Revenue By : Shri Rajesh Kumar, Cit Dr Date Of Hearing : 24.04.2024 Date Of Order : 04.06.2024 Order Per Shamim Yahya: This Appeal By The Assessee Is Directed Against The Order Of The Assessing Officer Dated 21.01.2022 Pursuant To The Directions Issued By The Drp For The Assessment Year 2017-18. 2. Grounds Of Appeal Taken By The Assessee Read As Under :-

section 270A of the Act. Each of the above grounds of appeal is without prejudice to and independent of one another.” 3. We have heard both the parties and perused the records. Both the parties have given written submissions which bring out the facts and respective arguments as under :- “SUBMISSIONS BY THE LD. COUNSEL FOR THE ASSESSEE : As submitted during

AYATNA REALTY PVT. LTD.,NEW DELHI vs. ACIT, CIRCLE-3(2), NEW DELHI

In the result, the appeal of the Assesse in ITA No

Bench: Shri Vikas Awasthy & Shri Manish Agarwalm/S Wrigley India Private Dcit, Limited Circle-27(2), 206, Okhla Industrial Vs. New Delhi. Estate, Phase Iii, New Delhi-110020 Pan-Aaacw1789P (Appellant) (Respondent) Joint Cit (Osd), M/S Wrigley India Private Circle-27(2), Limited, New Delhi Vs. 206, Okhla Industrial Estate, Phase Iii, New Delhi-110020 Pan-Aaacw1789P (Appellant) (Respondent)

transfer pricing adjustment of Rs.36,68,618/- made by the TPO which were upheld by the Ld. CIT(A). 10. The assessee had entered into the agreement with Wm. Wrigley Jr. Co., USA (“WWJC”) for research and development services on 01.01.2009. The WWJC engaged the assessee to conduct research, development, evaluation, planning and consulting activities and related business and technical

AYATNA REALTY PVT. LTD.,NEW DELHI vs. ACIT, CIRCLE-3(2), NEW DELHI

In the result, the appeal of the Assesse in ITA No

Bench: Shri Vikas Awasthy & Shri Manish Agarwalm/S Wrigley India Private Dcit, Limited Circle-27(2), 206, Okhla Industrial Vs. New Delhi. Estate, Phase Iii, New Delhi-110020 Pan-Aaacw1789P (Appellant) (Respondent) Joint Cit (Osd), M/S Wrigley India Private Circle-27(2), Limited, New Delhi Vs. 206, Okhla Industrial Estate, Phase Iii, New Delhi-110020 Pan-Aaacw1789P (Appellant) (Respondent)

transfer pricing adjustment of Rs.36,68,618/- made by the TPO which were upheld by the Ld. CIT(A). 10. The assessee had entered into the agreement with Wm. Wrigley Jr. Co., USA (“WWJC”) for research and development services on 01.01.2009. The WWJC engaged the assessee to conduct research, development, evaluation, planning and consulting activities and related business and technical

GREENLAND FINANCE AND LEASING P. LTD.,DELHI vs. ITO, NEW DELHI

In the result, the appeal of the Assesse in ITA No

Bench: Shri Vikas Awasthy & Shri Manish Agarwalm/S Wrigley India Private Dcit, Limited Circle-27(2), 206, Okhla Industrial Vs. New Delhi. Estate, Phase Iii, New Delhi-110020 Pan-Aaacw1789P (Appellant) (Respondent) Joint Cit (Osd), M/S Wrigley India Private Circle-27(2), Limited, New Delhi Vs. 206, Okhla Industrial Estate, Phase Iii, New Delhi-110020 Pan-Aaacw1789P (Appellant) (Respondent)

transfer pricing adjustment of Rs.36,68,618/- made by the TPO which were upheld by the Ld. CIT(A). 10. The assessee had entered into the agreement with Wm. Wrigley Jr. Co., USA (“WWJC”) for research and development services on 01.01.2009. The WWJC engaged the assessee to conduct research, development, evaluation, planning and consulting activities and related business and technical

GREENLAND FINANCE AND LEASING P. LTD.,DELHI vs. ITO, NEW DELHI

In the result, the appeal of the Assesse in ITA No

Bench: Shri Vikas Awasthy & Shri Manish Agarwalm/S Wrigley India Private Dcit, Limited Circle-27(2), 206, Okhla Industrial Vs. New Delhi. Estate, Phase Iii, New Delhi-110020 Pan-Aaacw1789P (Appellant) (Respondent) Joint Cit (Osd), M/S Wrigley India Private Circle-27(2), Limited, New Delhi Vs. 206, Okhla Industrial Estate, Phase Iii, New Delhi-110020 Pan-Aaacw1789P (Appellant) (Respondent)

transfer pricing adjustment of Rs.36,68,618/- made by the TPO which were upheld by the Ld. CIT(A). 10. The assessee had entered into the agreement with Wm. Wrigley Jr. Co., USA (“WWJC”) for research and development services on 01.01.2009. The WWJC engaged the assessee to conduct research, development, evaluation, planning and consulting activities and related business and technical

DCIT, CIRCLE-25(1), NEW DELHI vs. WRIGLEY INDIA P.LTD, NEW DELHI

In the result, the appeal of the Assesse in ITA No

transfer pricing adjustment of\nRs.36,68,618/- made by the TPO which were upheld by the Ld. CIT(A).\n10.\nThe assessee had entered into the agreement with Wm. Wrigley Jr. Co.,\nUSA (“WWJC\") for research and development services on 01.01.2009. The WWJC\nengaged the assessee to conduct research, development, evaluation, planning\nand consulting activities and related business and technical

WRIGLEY INDIA PVT. LTD.,206, OKHLA INDUSTRIAL ESTATE, PHASE-3,NEW DELHI-110020 vs. DCIT, CIRCLE 27(2), NEW DELHI

In the result, the appeal of the Assesse in ITA No

transfer pricing adjustment of\nRs.36,68,618/- made by the TPO which were upheld by the Ld. CIT(A).\n\n10. The assessee had entered into the agreement with Wm. Wrigley Jr. Co.,\nUSA (“WWJC") for research and development services on 01.01.2009. The WWJC\nengaged the assessee to conduct research, development, evaluation, planning\nand consulting activities and related business