COMMISSIONER OF INCOME TAX vs. MENTOR GRAPHICS (NOIDA) PVT.LTD

The appeal is allowed

Pricing Officer, in view of the provisions of section 92CA(3), was also required to follow the same methodology and approach as was incumbent upon the assessing officer under section 92C(3) of the said Act. In other words, the Transfer

(Now known as Sony India Limited)

Section 92B of the Income Tax Act, 1961. 3. Whether under Chapter X of the Income Tax Act, 1961, a 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 92B of the Income Tax Act, 1961? (iii) Whether under Chapter X of the Income Tax Act, 1961, a transfer pricing adjustment can be made by the Transfer Pricing Officer/ Assessing Officer in respect of expenditure treated as AMP Expenses and if so in which circumstances? (iv) If answer to question Nos.2 and 3

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 92B of the Income Tax Act, 1961? (iii) Whether under Chapter X of the Income Tax Act, 1961, a transfer pricing adjustment can be made by the Transfer Pricing Officer/ Assessing Officer in respect of expenditure treated as AMP Expenses and if so in which circumstances? (iv) If answer to question Nos.2 and 3

TUPPERWARE INDIA PRIVATE LIMITED,NEW DELHI vs. ACIT, CIRCLE-25(1) , NEW DELHI

In the result, the appeal of the assessee for AY 2018-19 is partly allowed for statistical purposes

Bench: Shri Mahavir Singh & Shri M. Balaganesh

Transfer Pricing Officer (TPO) under section 92CA(3) under section 143(3) read with section 144C(3) read with section

TUPPERWARE INDIA PRIVATE LIMITED,NEW DELHI vs. DCIT,CIRCLE-25(1), NEW DELHI

In the result, the appeal of the assessee for AY 2018-19 is partly allowed for statistical purposes

Bench: Shri Mahavir Singh & Shri M. Balaganesh

Transfer Pricing Officer (TPO) under section 92CA(3) under section 143(3) read with section 144C(3) read with section

KUNSHAN Q TECH MICROELECTRONICS (INDIA) PVT. LTD.,UTTAR PRADESH vs. DCIT, CENTRAL CIRCLE-30, DELHI

3,73,94,73,776/- without considering the Transfer Pricing Study of the assessee company and by wrongly computing the Arm's Length Price by adopting incorrect comparable as against the genuine comparable adopted by the assessee company in its Transfer Pricing Study and hence, the said erroneous addition needs to be deleted.\n12. That on the facts

ECOENERGY INSIGHTS LTD ( FORMERLY KNOWN AS CHUBB ALBA CONTROL SYSTEMS P.LTD),NEW DELHI vs. DCIT, CIRCLE-4(2), NEW DELHI

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

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaecoenergy Insights Ltd., Vs. Dcit, (Formerly Known As Chubb Alba Control Circle 4 (2), Systems P. Ltd.), New Delhi. Ground Floor, 18, Netaji Subhash Marg, Daryaganj, New Delhi – 110 002. (Pan :Aaaca0031C) (Appellant) (Respondent) Assessee By : Shri Nageshwar Rao, Advocate Shri Parth, Advocate Shri Pratik Rath, Advocate Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 12.08.2025 Date Of Order : 10.11.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Assessment Order Dated 25.07.2022Passed By The Assessment Unit, Income Tax Department Under Section 147 Read With Section 144C(13) R.W.S. 144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Ay 2018-19 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act.

price of international transactions. Further, the TPO as defined in explanation to section 92CA to be the person authorized by board to perform functions of AO specified in section 92C. In sub-section 3 of section 144B, roles of Technical unit is clearly spelt out according to which, functions of technical unit includes assistance or advice on transfer

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

Transfer Pricing Officer passed under sub–section (3) of section 92CA; and(ii) any foreign company.]”10.A reading of the aforesaid

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

Transfer Pricing officer (TPO) in relation to the international transaction between the respondent-assessee and its Associated Enterprise (AE). Draft assessment order under Section 144C(1) of the Act was passed on 31st December, 2010 and the respondent-assessee filed objections before the Dispute Resolution Panel (DRP). Thereafter, assessment under Section 143(3

THE COMMISSIONER OF INCOME TAX V vs. NAGESH KNITWEARS P. LTD.

transfer of Duty Free Replenishment Certificate, being the Duty Remission Scheme, under the export and import policy formulated and announced under section 5 of the Foreign Trade (Development and Regulation) Act, 1992 (22 of 1992);” 4. Sub-Section (3) of Section 80HHC and the Explanation (baa) read as under : “Section 80HHC- Deduction in respect of profits retained for export business

M/S TAKATA INDIA PVT. LTD.,,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Prakash Chand Yadav & Manish Agarwalassessment Year: 2011-12 Takata India Pvt Ltd., Vs. Dcit, Circle 25(1), (Now Joyson Anand Abhishek New Delhi Safety Systems Pvt Ltd.,) Plot No.20, Sector-5, Imt Manesar, Gurugram (Haryana)-122050 Pan/Gir No. Aacct 7200 N (Appellant) .. ( Respondent)

Transfer Pricing Officer) /Ld.DRP have erred in law and in facts and circumstances of the present case in not proving the benefit of deduction of +5% as per proviso to section 92C(2) of the Act.” 8. Ground No.1,2 & 3

ACIT, CIRCLE-8(1), NEW DELHI vs. EFS FACILITIES SERVICES (INDIA) PVT. LTD., NEW DELHI

In the result, both the appeals of the Revenue for assessment year

Bench: Dr. B.R.R. Kumar & Ms. Astha Chandra

price determined under sub- section (3) by the Transfer Pricing Officer.” The amended sub-section (4) provides that on receipt

ACIT, CIRCLE-8(1), NEW DELHI vs. EFS FACILITIES SERVICES (INDIA) PVT. LTD., NEW DELHI

In the result, both the appeals of the Revenue for assessment year

Bench: Dr. B.R.R. Kumar & Ms. Astha Chandra

price determined under sub- section (3) by the Transfer Pricing Officer.” The amended sub-section (4) provides that on receipt

BAXTER INDIA PRIVATE LIMITED,GURGAON, HARYANA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, NEW DELHI

In the result, appeals of the Assessee are allowed

Transfer pricing order under section 92CA(3) of the Act passed.\nDraft assessment order under section 144C of the Act passed

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any foreign company.]” 11. The fact that

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any foreign company.]” 11. The fact that

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any foreign company.]” 11. The fact that