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? 3. Whether under Chapter X of the Income Tax Act, 1961, a transfer pricing adjustment can be made by the Transfer 2015:DHC:10110-DB ITA Nos.110/2014 & 710/2015 Page 21 of 45

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? 3. Whether under Chapter X of the Income Tax Act, 1961, a transfer pricing adjustment can be made by the Transfer 2015:DHC:10110-DB ITA Nos.110/2014 & 710/2015 Page 21 of 45

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

Section 92F (v), an international transaction could include an arrangement, understanding or action in concert, this cannot be a matter of inference. There has to be some tangible evidence on record to show that two parties have "acted in concert". XXX XXX XXX 37. The provisions under Chapter X do envisage a 'separate entity concept'. In other words, there cannot

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

Section 92F (v), an international transaction could include an arrangement, understanding or action in concert, this cannot be a matter of inference. There has to be some tangible evidence on record to show that two parties have "acted in concert". XXX XXX XXX 37. The provisions under Chapter X do envisage a 'separate entity concept'. In other words, there cannot

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 92CA. Consequently, the reference appears to be invalid, and the transfer pricing and subsequent proceedings also appear to be time barred. In this context it is necessary to make following submissions – (a) time barring being a mandate to the forum, Hon’ble Tribunal may have to decide this preliminary aspect (b) assuming time barring aspect is decided in favour

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

price of such goods ; (e) "indirect costs" means costs, not being direct costs, allocated in the ratio of the export turnover in respect of trading goods to the total turnover ; (f) "trading goods" means goods which are not manufactured or processed by the assessee. xxx Explanation.--For the purposes of this sub-section,-- (baa) "profits of the business" means

TELETUBE ELECTRONICS LTD

The appeal of the Assessee is allowed

3. The Assessee Teletube Electronics Ltd. („TEL‟) had two divisions i.e. a picture tube division situated at Ghaziabad in Uttar Pradesh and a glass bulb division at Bhiwadi, Rajasthan for manufacturing glass shells/bulbs for domestic use. The said glass bulb division, which had three lines i.e. Line-I, Line-II and Line-III, became operational during

TELETUBE ELECTRONICS LTD

The appeal of the Assessee is allowed

3. The Assessee Teletube Electronics Ltd. („TEL‟) had two divisions i.e. a picture tube division situated at Ghaziabad in Uttar Pradesh and a glass bulb division at Bhiwadi, Rajasthan for manufacturing glass shells/bulbs for domestic use. The said glass bulb division, which had three lines i.e. Line-I, Line-II and Line-III, became operational during

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 of the Act. Explanatory Note to Finance (No. 2) Act: CBDT Circulars: 17. We have gone through the Circular No. 5/2010 dated 03.06.2010 which reads as under: “45

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 of the Act. Explanatory Note to Finance (No. 2) Act: CBDT Circulars: 17. We have gone through the Circular No. 5/2010 dated 03.06.2010 which reads as under: “45

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 of the Act. Explanatory Note to Finance (No. 2) Act: CBDT Circulars: 17. We have gone through the Circular No. 5/2010 dated 03.06.2010 which reads as under: “45

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 of the Act. Explanatory Note to Finance (No. 2) Act: CBDT Circulars: 17. We have gone through the Circular No. 5/2010 dated 03.06.2010 which reads as under: “45

DCIT, NEW DELHI vs. ISERVICES INVESTMENTS 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 of the Act. Explanatory Note to Finance (No. 2) Act: CBDT Circulars: 17. We have gone through the Circular No. 5/2010 dated 03.06.2010 which reads as under: “45

DCIT, NEW DELHI vs. M/S WICKWOOD DEVELOPMENT 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 of the Act. Explanatory Note to Finance (No. 2) Act: CBDT Circulars: 17. We have gone through the Circular No. 5/2010 dated 03.06.2010 which reads as under: “45

DCIT, NEW DELHI vs. M/S WICKWOOD DEVELOPMENT LTD.,, NEW DELHI

In the result, the Cross Objections of the assessees are\nallowed and consequently the appeals of the revenue are liable\nto be dismissed

Transfer Pricing Officer passed\nunder sub-section (3) of section 92CA; and\n(ii) any foreign company.]\"\n15. A plain reading of Section indicates that it is obligatory on\nthe part of the AO to forward a draft Assessment Order as per\nthe provisions of Section 144C(1) of the Act. The sub-Section\n(1) of Section 144C being

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)

3 of the Revenue. 11. Ground No. 4 of the Revenue is in respect of disallowance of deduction u/s 80IB/IC by applying provisions of Section 80IB/IC by applying provisions of Section 80IA(8) in respect of transfer of goods (Katha & Supari) from Noida division to eligible undertaking. The Coordinate Bench of this Tribunal vide order dated 07/10/2020 in assessee

DCIT, NEW DELHI vs. M/S. NEWBURY HOLDING TWO LTD., NEW DELHI

In the result, the Cross Objections of the assessees are\nallowed and consequently the appeals of the revenue are liable\nto be dismissed

Transfer Pricing Officer passed\nunder sub-section (3) of section 92CA; and\n(ii) any foreign company.]\"\n15. A plain reading of Section indicates that it is obligatory on\nthe part of the AO to forward a draft Assessment Order as per\nthe provisions of Section 144C(1) of the Act. The sub-Section\n(1) of Section 144C being

ADOBE SYSTEMS SOFTWARE IRELAND LIMITED,IRELAND vs. ACIT CIRCLE 1(1)(1) INTERNATIONAL TAXATION, NEW DELHI

In the result, the appeal of the assessee is treated as allowed for statistical purposes subject to the directions contained in para 11, 18 and 19 above

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2020-21

3 ‘income from income tax interest’ in its return of income aggregating to total amount of Rs. 45,80,35,328/-. Other receipts viz. receipts from software supply and automated services are claimed non-taxable in India by the assessee. The case of the assessee was not referred to the Ld. Transfer Pricing Officer