MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

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

transfer pricing provisions. The meaning assigned to ‘international transaction’ in terms of Clause (iv) of Section 92B was inclusive and not limited to the types of transactions in sub-clauses A to C and E of Clause (i). The bright line test was a way of finding out the cost and value of the international transaction, which was the first

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

transfer pricing provisions. The AO allowed only 2% of turnover and balance was disallowed under section 40A(2) of the Act. On these

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

transfer pricing provisions. The AO allowed only 2% of turnover and balance was disallowed under section 40A(2) of the Act. On these

BAUSCH & LOMB EYECARE (INDIA) PVT. LTD.

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

Transfer Pricing Officer by applying the parameters specified in paragraph 17.4 of the order dated 23.01.2013 passed by the Special Bench in the case of LG Electronics India (P) Ltd.?” 20. The conclusions of the Division Bench in Sony Ericsson (supra) are as under: (i) The Court concurred with the majority of the Special Bench of the ITAT

BAUSCH & LOMB EYECARE (INDIA) PVT. LTD.

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

Transfer Pricing Officer by applying the parameters specified in paragraph 17.4 of the order dated 23.01.2013 passed by the Special Bench in the case of LG Electronics India (P) Ltd.?” 20. The conclusions of the Division Bench in Sony Ericsson (supra) are as under: (i) The Court concurred with the majority of the Special Bench of the ITAT

BAUSCH & LOMB EYECARE (INDIA) PVT. LTD.

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

Transfer Pricing Officer by applying the parameters specified in paragraph 17.4 of the order dated 23.01.2013 passed by the Special Bench in the case of LG Electronics India (P) Ltd.?” 20. The conclusions of the Division Bench in Sony Ericsson (supra) are as under: (i) The Court concurred with the majority of the Special Bench of the ITAT

BAUSCH & LOMB EYECARE (INDIA) PVT. LTD.

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

Transfer Pricing Officer by applying the parameters specified in paragraph 17.4 of the order dated 23.01.2013 passed by the Special Bench in the case of LG Electronics India (P) Ltd.?” 20. The conclusions of the Division Bench in Sony Ericsson (supra) are as under: (i) The Court concurred with the majority of the Special Bench of the ITAT

BAUSCH & LOMB EYECARE (INDIA) PVT. LTD.

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

Transfer Pricing Officer by applying the parameters specified in paragraph 17.4 of the order dated 23.01.2013 passed by the Special Bench in the case of LG Electronics India (P) Ltd.?” 20. The conclusions of the Division Bench in Sony Ericsson (supra) are as under: (i) The Court concurred with the majority of the Special Bench of the ITAT

BAUSCH & LOMB EYECARE (INDIA) PVT. LTD.

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

Transfer Pricing Officer by applying the parameters specified in paragraph 17.4 of the order dated 23.01.2013 passed by the Special Bench in the case of LG Electronics India (P) Ltd.?” 20. The conclusions of the Division Bench in Sony Ericsson (supra) are as under: (i) The Court concurred with the majority of the Special Bench of the ITAT

BAUSCH & LOMB EYECARE (INDIA) PVT. LTD.

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

Transfer Pricing Officer by applying the parameters specified in paragraph 17.4 of the order dated 23.01.2013 passed by the Special Bench in the case of LG Electronics India (P) Ltd.?” 20. The conclusions of the Division Bench in Sony Ericsson (supra) are as under: (i) The Court concurred with the majority of the Special Bench of the ITAT

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

transfer of steam has taken though additional grounds\n\nPage | 42\n\nof appeal be admitted and additional evidences filed in support of\nthe additional claim may deserves to be admitted in the interest of\njustice.\n\n44. On the other hand, Ld. CIT DR seriously objected the\nadmission of additional grounds as well as admission of additional\nevidences

SAMSUNG INDIA ELECTRONICS PVT. LTD.,GURGAON vs. DCIT CIRCLE-22(2), NEW DELHI

In the result, the appeal of the assessee is partly allowed in the aforesaid manner

Bench: Shri G. S. Pannu & Shri Yogesh Kumar U.S.

transfer pricing proceedings, the TPO had vide a show-cause notice (SCN) dated 17 September 2018 rejected the TNMM analysis (aggregated approach) adopted by the assessee. Instead, the TPO chose to apply the CUP method and thereby proposed three third party royalty agreements (with an ALP of 1.50%). This SCN was responded to vide 33 Samsung India Electronics. submission dated

UCWEB MOBILE PRIVATE LIMITED,GURGAON vs. ASSESSMENT UNIT, INOCOME TAX DEPARTMENT, GURGAON

In the result, the appeal of the assessee is partly allowed

Bench: SHRI MAHAVIR SINGH (Vice President), SHRI MANISH AGARWAL (Accountant Member)

transfer pricing adjustment of AMP expenses as invalid. Further, the Hon’ble High Court in the case of CIT vs Whirlpool of India Ltd. [2016] 381 ITR 154 (Delhi) held as under:- 39. “It is in this context that it is submitted, and rightly, by the Assessee that there must be a machinery provision in the Act to bring

HONDA SIEL POWER PRODUCTS LIMITED vs. DEPUTY COMMISSIONER OF INCOME TAX

The appeal is allowed but in the circumstances no orders as to

Transfer Pricing Officer by applying the parameters specified in paragraph 17.4 of the order dated 23.01.2013 passed by the Special Bench in the case of LG Electronics India (P) Ltd.?” 13. The summary of the conclusions of the Division Bench in Sony Ericsson (supra) was as under: (i) The Court concurred with the majority of the Special Bench

DLF URBAN PVT LTD,NEW DELHI vs. ACIT,CIRCLE,7(1),, NEW DELHI

Bench: Shri Shamim Yahya & Shri Anubhav Sharmaassessment Year: 2016-17 Dcit, Vs Dlf Urban Pvt. Ltd., Circle 7(1), 15, Shivaji Marg, New Delhi. New Delhi – 110 015 Pan: Aafcd3019C Assessment Year: 2016-17 Dlf Urban Pvt. Ltd., Vs. Dcit, 15, Shivaji Marg, Circle 7(1), New Delhi – 110 015 New Delhi. Pan: Aafcd3019C (Appellants) (Respondents) Assessee By : Shri R.S. Singhvi, Shri Satyajeet Goel & Shri Rajat Garg, Cas. Revenue By : Shri Rajesh Kumar, Cit, Dr Date Of Hearing : 23.02.2024 Date Of Pronouncement : 08.04.2024 Order Per Anubhav Sharma, Jm: These Are Cross Appeals Preferred By The Assessee & The Revenue Against The Order Dated 30.06.2022 Of The Commissioner Of Income-Tax

transfer pricing proceedings. The appellant had itself shown the transaction of purchase of development right in land as expenditure in respect of which payment has been made to any person referred to in section 40A

AMAZON SMART COMMERCE SOLUTIONS PRIVATE LIMITED,DELHI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, DELHI-1, DELHI

In the result, grounds raised by the assessee are dismissed

transfer pricing provisions as well as section 40A(2) of the Act. However, the AO has not raised any query

VENETIAN LDF PROJECTS LLP,GURGAON vs. ACIT CIRCLE-4(1), GURGAON

In the result, grounds raised by the assessee are dismissed

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

transfer pricing provisions as well as section 40A(2) of the Act. However, the AO has not raised any query

THE COMMISSIONER OF INCOME TAX-LTU vs. WHIRLPOOL OF INDIA LTD

transfer pricing adjustment is made by substituting the ALP for the price of the transaction. To begin with there has to be an international transaction with a certain disclosed price. The TP adjustment envisages the substitution of the price of such international transaction with the ALP. 34. The TP adjustment is not expected to be made by deducing from