MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

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

5. Whether the Income Tax Appellate Tribunal was right in directing that fresh bench marketing/comparability analysis should be undertaken by the Transfer Pricing Officer by applying the parameters specified in paragraph17.4 of the order dated 23.01.2013 passed by the Special Bench in the case of LG Electronics India (P) Ltd. v. ACIT? 32. However, on the next date i.e. 30th

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

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

5. Whether the Income Tax Appellate Tribunal was right in directing that fresh bench marketing/comparability analysis should be undertaken by the Transfer Pricing Officer by applying the parameters specified in paragraph17.4 of the order dated 23.01.2013 passed by the Special Bench in the case of LG Electronics India (P) Ltd. v. ACIT? 32. However, on the next date i.e. 30th

DCIT, CC-29, NEW DELHI vs. DHARAMPAL SATYALPAL LTD., NEW DELHI

Bench: Shri G. S. Pannu & Shri Yogesh Kumar U.S.I.T.A. No. 1977/Del/2020 (A.Y 2014-15)

43[For purposes of this sub-section, "market value", in relation to any goods or services, means- price that such goods or services would ordinarily fetch in (i) open market; or arm's length price as defined in clause (ii) of section 92F, where (ii) transfer of such goods or services is a specified domestic transaction referred to in section

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.

section 1448 would show that there is no provision for Technical Unit to make reference to TPO, as Technical Unit itself is authorised to perform functions of providing technical assistance for transfer pricing. Further delegation by one TPO (Technical Unit under faceless regime) to TPO (erstwhile physical assessment regime) is not permissible on a plain reading of provisions

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

43 where an assessee has failed or not furnished a report in respect of an international transaction, a specific reference for the said transaction under sub-section (1) is not required. It is sufficient, if arm's length pricing issue of any international transaction has been referred to the TPO..... 52. The contention that AMP expenses are not international transactions

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

43 where an assessee has failed or not furnished a report in respect of an international transaction, a specific reference for the said transaction under sub-section (1) is not required. It is sufficient, if arm's length pricing issue of any international transaction has been referred to the TPO..... 52. The contention that AMP expenses are not international transactions

M/S GEODIS OVERSEAS PVT. LTD.,,GURGAON vs. DCIT,, NEW DELHI

In the result, both the appeals are partly allowed for statistical purposes

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarita No. 3195/Del/2017 Assessment Year: 2003-04 Ita No. 3196/Del/2017 Assessment Year: 2004-05 Geodis Overseas Pvt.Ltd., Vs. Asstt. Commissioner Of Building No.5,Tower B, Income Tax, 10Th Floor, Dlf Cyber City, Company Circle- Ii(1), Phase Iii, Gurgaon Chennai-34 Pin: 122 002 Pan No. Aaacc6168L (Appellant) (Respondent)

Transfer Pricing Officer passed order under section 92CA(3) on 22-02-2006 wherein he determined an adjustment of Rs.2,23,96,778/- to be made to the value of international transactions entered into by the assessee. Hence, a sum of Rs.2,23,96,778/- is reduced from the loss shown by the assessee. 5. The assessee has claimed

DR. BHIM RAO AMBEDKAR MAHASANG HARYANA,FARIDABAD vs. CIT (EXEMPTIONS), CHANDIGARH/FARIDABAD

In the result, both the appeals are partly allowed for statistical purposes

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarita No. 3195/Del/2017 Assessment Year: 2003-04 Ita No. 3196/Del/2017 Assessment Year: 2004-05 Geodis Overseas Pvt.Ltd., Vs. Asstt. Commissioner Of Building No.5,Tower B, Income Tax, 10Th Floor, Dlf Cyber City, Company Circle- Ii(1), Phase Iii, Gurgaon Chennai-34 Pin: 122 002 Pan No. Aaacc6168L (Appellant) (Respondent)

Transfer Pricing Officer passed order under section 92CA(3) on 22-02-2006 wherein he determined an adjustment of Rs.2,23,96,778/- to be made to the value of international transactions entered into by the assessee. Hence, a sum of Rs.2,23,96,778/- is reduced from the loss shown by the assessee. 5. The assessee has claimed

PCL FOODS PVT. LTD.,GURGAON vs. ADDI CIT, NATIONAL E- ASSESMENT CENTRE, NEW DELHI

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

Bench: Ms. Madhumita Roy & Shri Brajesh Kumar Singh[Assessment Year: 2016-17] Pcl Foods Private Limited, Additional / Joint/ Unit No.-219, Plot No. 2, Deputy/Assistant Vardhman Crown Mall, Lsc, Vs Commissioner Of Income Sector 19, Dwarka, New Tax/ Income Tax Officer, Delhi-110075. National E-Assessment Centre, Delhi. Pan- Aahcp3493L Assessee Revenue

transfer pricing study initially identified only one comparable, namely M/s Sakuma Exports Ltd., and applied the Transactional Net Margin Method (TNMM) as the most appropriate method. The TPO observed that the assessee's business of rice trading is not of such a unique or specialized nature as to warrant only a single comparable and further noted that the turnover filter

MUFG BANK,LTD (EARLIER KNOWN AS THE BANK OF TOKYO MITSUBISHI UFJ LTD.),NEW DELHI vs. ACIT, CIRCLE-2(2)(1) INT. TAXATION, DELHI

In the result, the appeal of the assessee is allowed in above terms

Bench: Shri Pradip Kumar Kedia & Shri Narender Kumar Choudhry

5) of the Act vide order dated 23.02.2022 confirming the action of the TPO without any relief. The AO, in turn, its final order in pursuance of directions of DRP passed order dated 29.04.2022 and reiterated the additions of Rs.13,66,36,734/- towards transfer pricing adjustment on account of counter guarantee commission received from AE, applying arm length principles

DCIT, CC-29, NEW DELHI vs. DHARAMPAL SATYAPAL LTD., NEW DELHI

Bench: Shri G. S. Pannu & Shri Yogesh Kumar U.S.I.T.A. No. 1976/Del/2020 (A.Y 2013-14)

43[For purposes of this sub-section, "market value", in relation to any goods or services, means- price that such goods or services would ordinarily fetch in (i) open market; or arm's length price as defined in clause (ii) of section 92F, where (ii) transfer of such goods or services is a specified domestic transaction referred to in section

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

5 per cent of sale of goods. In case where tax rate was more than 5 per cent including additional tax, the balance was to be paid by the unit. Para7 (2) of the notification provides for the exemption of sales tax to the extent of exemption or reduction in tax. Item (2) of the Schedule includes Greater Noida Industrial

LG ELECTRONICS INDIA PRIVATE LIMITED ,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

5 per cent of sale of goods. In case where tax rate was more than 5 per cent including additional tax, the balance was to be paid by the unit. Para7 (2) of the notification provides for the exemption of sales tax to the extent of exemption or reduction in tax. Item (2) of the Schedule includes Greater Noida Industrial

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

5 per cent of sale of goods. In case where tax rate was more than 5 per cent including additional tax, the balance was to be paid by the unit. Para7 (2) of the notification provides for the exemption of sales tax to the extent of exemption or reduction in tax. Item (2) of the Schedule includes Greater Noida Industrial

M/S LG ELECTRONICS INDIA PVT. LTD.,,NEW DELHI vs. DCIT, NOIDA

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

5 per cent of sale of goods. In case where tax rate was more than 5 per cent including additional tax, the balance was to be paid by the unit. Para7 (2) of the notification provides for the exemption of sales tax to the extent of exemption or reduction in tax. Item (2) of the Schedule includes Greater Noida Industrial

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

5 per cent of sale of goods. In case where tax rate was more than 5 per cent including additional tax, the balance was to be paid by the unit. Para7 (2) of the notification provides for the exemption of sales tax to the extent of exemption or reduction in tax. Item (2) of the Schedule includes Greater Noida Industrial

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

5 per cent of sale of goods. In case where tax rate was more than 5 per cent including additional tax, the balance was to be paid by the unit. Para7 (2) of the notification provides for the exemption of sales tax to the extent of exemption or reduction in tax. Item (2) of the Schedule includes Greater Noida Industrial

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

5 per cent of sale of goods. In case where tax rate was more than 5 per cent including additional tax, the balance was to be paid by the unit. Para7 (2) of the notification provides for the exemption of sales tax to the extent of exemption or reduction in tax. Item (2) of the Schedule includes Greater Noida Industrial