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202 results for “transfer pricing”+ Section 43Bclear

Sorted by relevance

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Key Topics

Section 143(3)98Addition to Income76Section 92C56Section 43B55Disallowance54Deduction50Transfer Pricing43Section 14A37Section 80G29Section 154

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

Appeal of the assessee is partly allowed for statistical purpose

ITA 467/DEL/2014[2009-10]Status: DisposedITAT Delhi17 Oct 2018AY 2009-10

Bench: Shri R. K. Panda & Ms Suchitra Kamblei.T.A .No. 467/Del/2014 (A.Y 2009-10)

Section 143(3)Section 144CSection 144C(5)Section 43Section 43B

Transfer Pricing Officer (TPO). The TPO vide order dated 21.01.2013 made following adjustments to the returned income of the assessee: 1 Adjustment on account of payment of royalty for use Rs. 311.74 cr. of brand name 2 Adjustment on account of AMP Rs. 136 cr. Total Adjustment to be made Rs. 447.74 cr. Draft Assessment Order was passed

RANBAXY LABORATORIES LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

Showing 1–20 of 202 · Page 1 of 11

...
27
Section 144C25
Section 115J24

In the result, we direct the AO to reduce the book profit u/s 115JB of the Act by the amount of reversal of the provision of Rs

ITA 196/DEL/2013[2008-09]Status: DisposedITAT Delhi25 Apr 2016AY 2008-09

Bench: Sh. I. C.Sudhir Judicialmember & Sh. Prashant Maharishia.Y.: - 2008-09 Ranbaxy Laboratories Ltd. Vs Acit 12Th Floor, Devika Tower, Range -15 6, Nehru Place New Delhi New Delhi Pan No. Aaacr0127N (Appellant) (Respondent)

For Appellant: 1. Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Amrendra Kumar, CIT, DR
Section 143Section 143(3)Section 92D

transfer pricing for developing countries had observed that ‗It may be the local or the foreign party‘, we tend to agree with the same.‖ 34. Above decision reproduced by us covers many divergent views of the coordinate benches and after considering them coordinate bench has reiterated all the principles noted by us for selection of tested party. Hence, we also

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

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

ITA 6021/DEL/2012[2008-09]Status: DisposedITAT Delhi09 Nov 2017AY 2008-09

Bench: Shri N.K. Saini & Shri K.N. Charry

Section 143(3)Section 144CSection 144C(5)Section 14ASection 35DSection 43BSection 92C

Transfer Pricing Officer u/s 92CA(1) of the Act and the TPO made the adjustment on account of royalty for use of brand name to a tune of Rs. 2,37,24,42,202/- and in respect of AMP service to a tune of Rs. 1,95,16,00,000/-, thus, totaling to Rs. 4,32,40,42,202/-. Draft

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

Appeal is allowed

ITA 5720/DEL/2011[2007-08]Status: DisposedITAT Delhi12 Jul 2016AY 2007-08

Bench: Shri I.C. Sudhir & Shri L.P. Sahu Assessment Year: 2007-08 Assessment Year: 2007-08 Maruti Suzuki India Ltd., Vs. Additional Cit, Plot No.1, Nelson Mandela Road, Range-6, Vasant Road, New Delhi. New Delhi. (Pan: Aaacm0829Q) (Appellant) (Respondent) Assessee By: S/Shri Ajay Vohra, Sr. Adv. Neeraj Jain, Rohit Jain, Adv. Romit Katyal & Ms. Tejasvi Jain, Cas Department By:Shri Amrendra Kumar, Cit(Dr)

For Appellant: S/Shri Ajay Vohra, Sr. Adv. NeerajFor Respondent: Shri Amrendra Kumar, CIT(DR)

section 43B necessarily had to be allowed by the AO. 15 That the assessing officer erred on facts and in law in making addition to the income of the appellant to the extent of Rs. 463.12 on account of the alleged difference in the arm’s length price of international transactions. 15.1 That the assessing officer erred on facts

ACIT (LTU), NEW DELHI vs. MAX NEW YORK LIFE INSURANCE COMPANY LTD., NEW DELHI

In the result, the appeal is allowed for statistical purposes

ITA 1768/DEL/2011[2002-03]Status: DisposedITAT Delhi17 Oct 2017AY 2002-03

Bench: Shri R.S. Syal & Shri Sudhanshu Srivastavaassessment Year : 2002-03

For Appellant: Shri M.S. Syali, Sr. Advocate &For Respondent: Shri Amrendra Kumar, CIT, DR

43B, and then secondly, by computing income in terms of section 92 of the Act, by making addition on account of transfer pricing

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

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

ITA 4081/DEL/2010[2003-04]Status: PendingITAT Delhi12 Mar 2024AY 2003-04

Bench: Shri Saktijit Dey & Shri N.K. Billaiya

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Rajesh Kumar, CIT-DR

Transfer Pricing adjustment in respect of international transactions entered into during the year. 8. Briefly stated, the assessee is a subsidiary of Suzuki Motor Corporation, Japan with a 45.54% shareholding of the Government of India and is engaged in the manufacture and sale of passenger cars primarily for sale in Indian market. It also exports vehicles and spare part

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

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

ITA 991/DEL/2016[2011-12]Status: DisposedITAT Delhi15 Oct 2025AY 2011-12

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

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

ITA 430/DEL/2024[2006-07]Status: DisposedITAT Delhi15 Oct 2025AY 2006-07

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

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

ITA 433/DEL/2024[2005-06]Status: DisposedITAT Delhi15 Oct 2025AY 2005-06

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

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

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

ITA 2035/DEL/2021[2007-08]Status: DisposedITAT Delhi15 Oct 2025AY 2007-08

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

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

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

ITA 1969/DEL/2016[2011-12]Status: DisposedITAT Delhi15 Oct 2025AY 2011-12

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

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

ITA 1267/DEL/2020[2007-08]Status: DisposedITAT Delhi15 Oct 2025AY 2007-08

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

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

ITA 9000/DEL/2019[2014-15]Status: DisposedITAT Delhi15 Oct 2025AY 2014-15

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

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

ITA 6838/DEL/2017[2012-13]Status: DisposedITAT Delhi15 Oct 2025AY 2012-13

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

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

ITA 7424/DEL/2018[2013-14]Status: DisposedITAT Delhi15 Oct 2025AY 2013-14

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent

ARICENT TECHNOLOGIES (HOLDINGS) LTD.,NEW DELHI vs. JCIT, SPECIAL RANGE- 1 , NEW DELHI

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

ITA 7112/DEL/2017[2013-14]Status: DisposedITAT Delhi29 Nov 2019AY 2013-14

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

For Appellant: Sh. Ajay Vohra, Sr.Adv. &For Respondent: Sh. Sanjay I.Bara, CIT DR
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 92C

price of international transaction on payment of corporate charges on an adhoc and arbitrary basis without applying any of the methods prescribed under section 92C of the Act. 2. That on the facts and circumstances of the case and in law, the Ld. CIT(A) erred in not entertaining the claim of deduction of Rs.2,77,79,494 under section

ARIVENT TECHNOLOGIES HOLDINGS LTD.,NEW DELHI vs. DCIT, NEW DELHI

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

ITA 1308/DEL/2015[2010-11]Status: DisposedITAT Delhi29 Nov 2019AY 2010-11

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

For Appellant: Sh. Ajay Vohra, Sr.Adv. &For Respondent: Sh. Sanjay I.Bara, CIT DR
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 92C

price of international transaction on payment of corporate charges on an adhoc and arbitrary basis without applying any of the methods prescribed under section 92C of the Act. 2. That on the facts and circumstances of the case and in law, the Ld. CIT(A) erred in not entertaining the claim of deduction of Rs.2,77,79,494 under section

ARICENT TECHNOLOGIES (HOLDINGS) LTD.,NEW DELHI vs. DCIT, CIRCLE- 3(1), NEW DELHI

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

ITA 4913/DEL/2018[2011-12]Status: DisposedITAT Delhi29 Nov 2019AY 2011-12

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

For Appellant: Sh. Ajay Vohra, Sr.Adv. &For Respondent: Sh. Sanjay I.Bara, CIT DR
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 92C

price of international transaction on payment of corporate charges on an adhoc and arbitrary basis without applying any of the methods prescribed under section 92C of the Act. 2. That on the facts and circumstances of the case and in law, the Ld. CIT(A) erred in not entertaining the claim of deduction of Rs.2,77,79,494 under section

ARICENT TECHNOLOGIES (HOLDINGS) LTD.,NEW DELHI vs. ADDL. CIT, SPECIAL RANGE- 1 , NEW DELHI

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

ITA 7637/DEL/2018[2014-15]Status: DisposedITAT Delhi29 Nov 2019AY 2014-15

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

For Appellant: Sh. Ajay Vohra, Sr.Adv. &For Respondent: Sh. Sanjay I.Bara, CIT DR
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 92C

price of international transaction on payment of corporate charges on an adhoc and arbitrary basis without applying any of the methods prescribed under section 92C of the Act. 2. That on the facts and circumstances of the case and in law, the Ld. CIT(A) erred in not entertaining the claim of deduction of Rs.2,77,79,494 under section

M/S. ARICENT TECHNOLOGIES (HOLDINGS) LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

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

ITA 1944/DEL/2017[2012-13]Status: DisposedITAT Delhi29 Nov 2019AY 2012-13

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

For Appellant: Sh. Ajay Vohra, Sr.Adv. &For Respondent: Sh. Sanjay I.Bara, CIT DR
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 92C

price of international transaction on payment of corporate charges on an adhoc and arbitrary basis without applying any of the methods prescribed under section 92C of the Act. 2. That on the facts and circumstances of the case and in law, the Ld. CIT(A) erred in not entertaining the claim of deduction of Rs.2,77,79,494 under section