DCIT, NEW DELHI vs. DCM SHRIRAM LTD, NEW DELHI

391\n3.\nRental expenditure\n4,28,13,157\n4.\nDirector’s Remuneration\n13,08,54,514\n5.\nRemuneration paid to relative of director\n41,56,788\n6.\nDirector’s sitting fees\n15,35,000\n7.\nCommission paid to directors\n1,29,49,000\n8.\nPurchase of Goods (PVC Compounds)\n5,57,003\nTotal

DCM SHRIIRAM LIMITED,NEW DELHI vs. NEAC, NEW DELHI

391\n\n3.\n\nRental expenditure\n\n4,28,13,157\n\n4.\n\nDirector’s Remuneration\n\n13,08,54,514\n\n5.\n\nRemuneration paid to relative of director\n\n41,56,788\n\n6.\n\nDirector’s sitting fees\n\n15,35,000\n\n7.\n\nCommission paid to directors

HEWITT ASSOCIATES (INDIA) PVT. LTD.,GURGAON vs. ACIT, NEW DELHI

In the result, the appeal of the assesee is treated as allowed for statistical purposes

Bench: Shri R.K. Panda & Ms. Astha Chandraasstt. Year : 2007-08

391,931,625 Difference/ adjustment 22,11,60,596 5. The Ld. AO in his final assessment order dated 31.10.2011 enhanced the income of the assessee by making addition of Rs. 41,20,14,305/- proposed by the Ld. TPO. 6. The Hon’ble Dispute Resolution Panel (“DRP”) vide its order dated 20.9.2011 confirmed the transfer pricing adjustment

GLOBAL GREEN COMPANY LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeals of the assessee are partly allowed for statistical purpose and the appeals of the revenue are dismissed

Bench: Sh. C. N. Prasaddr. B. R. R. Kumar

transfer pricing addition of Rs. 7,90,535/- made by the AO/TPO in respect of transaction of purchase of packing materials from an associated enterprise. 4.2 The Appellant humbly prays that since the purchase price at which the Appellant has entered into the international transaction of purchase of packing material is less than the ALP determined

DCIT, CIRCLE- 10(1), NEW DELHI vs. GLOBAL GREEN COMPANY LTD., NEW DELHI

In the result, the appeals of the assessee are partly allowed for statistical purpose and the appeals of the revenue are dismissed

Bench: Sh. C. N. Prasaddr. B. R. R. Kumar

transfer pricing addition of Rs. 7,90,535/- made by the AO/TPO in respect of transaction of purchase of packing materials from an associated enterprise. 4.2 The Appellant humbly prays that since the purchase price at which the Appellant has entered into the international transaction of purchase of packing material is less than the ALP determined

GLOBAL GREEN COMPANY LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeals of the assessee are partly allowed for statistical purpose and the appeals of the revenue are dismissed

Bench: Sh. C. N. Prasaddr. B. R. R. Kumar

transfer pricing addition of Rs. 7,90,535/- made by the AO/TPO in respect of transaction of purchase of packing materials from an associated enterprise. 4.2 The Appellant humbly prays that since the purchase price at which the Appellant has entered into the international transaction of purchase of packing material is less than the ALP determined

GLOBAL GREEN COMPANY LTD.,NEW DELHI vs. DCIT, CIRCLE- 10(1), NEW DELHI

In the result, the appeals of the assessee are partly allowed for statistical purpose and the appeals of the revenue are dismissed

Bench: Sh. C. N. Prasaddr. B. R. R. Kumar

transfer pricing addition of Rs. 7,90,535/- made by the AO/TPO in respect of transaction of purchase of packing materials from an associated enterprise. 4.2 The Appellant humbly prays that since the purchase price at which the Appellant has entered into the international transaction of purchase of packing material is less than the ALP determined

GLOBAL GREEN COMPANY LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeals of the assessee are partly allowed for statistical purpose and the appeals of the revenue are dismissed

Bench: Sh. C. N. Prasaddr. B. R. R. Kumar

transfer pricing addition of Rs. 7,90,535/- made by the AO/TPO in respect of transaction of purchase of packing materials from an associated enterprise. 4.2 The Appellant humbly prays that since the purchase price at which the Appellant has entered into the international transaction of purchase of packing material is less than the ALP determined

DCIT, NEW DELHI vs. M/S GLOBAL GREEN COMPANY LTD.,, NEW DELHI

In the result, the appeals of the assessee are partly allowed for statistical purpose and the appeals of the revenue are dismissed

Bench: Sh. C. N. Prasaddr. B. R. R. Kumar

transfer pricing addition of Rs. 7,90,535/- made by the AO/TPO in respect of transaction of purchase of packing materials from an associated enterprise. 4.2 The Appellant humbly prays that since the purchase price at which the Appellant has entered into the international transaction of purchase of packing material is less than the ALP determined

GLOBAL GREEN COMPANY LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeals of the assessee are partly allowed for statistical purpose and the appeals of the revenue are dismissed

Bench: Sh. C. N. Prasaddr. B. R. R. Kumar

transfer pricing addition of Rs. 7,90,535/- made by the AO/TPO in respect of transaction of purchase of packing materials from an associated enterprise. 4.2 The Appellant humbly prays that since the purchase price at which the Appellant has entered into the international transaction of purchase of packing material is less than the ALP determined

GLOBAL GREEN COMPANY LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeals of the assessee are partly allowed for statistical purpose and the appeals of the revenue are dismissed

Bench: Sh. C. N. Prasaddr. B. R. R. Kumar

transfer pricing addition of Rs. 7,90,535/- made by the AO/TPO in respect of transaction of purchase of packing materials from an associated enterprise. 4.2 The Appellant humbly prays that since the purchase price at which the Appellant has entered into the international transaction of purchase of packing material is less than the ALP determined

DCIT, NEW DELHI vs. M/S GLOBAL GREEN COMPANY LTD.,, NEW DELHI

In the result, the appeals of the assessee are partly allowed for statistical purpose and the appeals of the revenue are dismissed

Bench: Sh. C. N. Prasaddr. B. R. R. Kumar

transfer pricing addition of Rs. 7,90,535/- made by the AO/TPO in respect of transaction of purchase of packing materials from an associated enterprise. 4.2 The Appellant humbly prays that since the purchase price at which the Appellant has entered into the international transaction of purchase of packing material is less than the ALP determined

GLOBAL GREEN COMPANY LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeals of the assessee are partly allowed for statistical purpose and the appeals of the revenue are dismissed

Bench: Sh. C. N. Prasaddr. B. R. R. Kumar

transfer pricing addition of Rs. 7,90,535/- made by the AO/TPO in respect of transaction of purchase of packing materials from an associated enterprise. 4.2 The Appellant humbly prays that since the purchase price at which the Appellant has entered into the international transaction of purchase of packing material is less than the ALP determined

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

Section 80IA of the Act. 60. In view of the above, the questions of law are answered in favour of the Assessee and against the Revenue”. 52. Further, the Ld. AR submitted that the issue under consideration is identical to the issue involved in case of DCM Shriram Ltd for AY 2014-15, wherein relief has already been granted

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

Section 80IA of the Act. 60. In view of the above, the questions of law are answered in favour of the Assessee and against the Revenue”. 52. Further, the Ld. AR submitted that the issue under consideration is identical to the issue involved in case of DCM Shriram Ltd for AY 2014-15, wherein relief has already been granted

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

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

Section 80IA of the Act. 60. In view of the above, the questions of law are answered in favour of the Assessee and against the Revenue”. 52. Further, the Ld. AR submitted that the issue under consideration is identical to the issue involved in case of DCM Shriram Ltd for AY 2014-15, wherein relief has already been granted

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)

Section 92F(5) of the Act, if ITA No.1293 to1295/Del/2022 there is an arrangement, understanding or action in concert, whether or not such arrangement, is in action formal or in writing which shows to substantiate in a transaction between two AEs, transfer pricing provisions would apply, and the transaction would qualify as an international transaction. Further, in the instant case

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)

Section 92F(5) of the Act, if ITA No.1293 to1295/Del/2022 there is an arrangement, understanding or action in concert, whether or not such arrangement, is in action formal or in writing which shows to substantiate in a transaction between two AEs, transfer pricing provisions would apply, and the transaction would qualify as an international transaction. Further, in the instant case