DCIT, NEW DELHI vs. M/S. BBC WORLD INDIA (P) LTD., NEW DELHI

In the result appeal of the assessee and the learned assessing officer are allowed for statistical purposes

Bench: Shri Kuldip Singh & Shri Prashant Maharishi

section 144C(5) of the Act did not allow reasonable opportunity to the Appellant to fight the case on merits. The directions of the DRP are erroneous and perverse on facts. Transfer Pricing ("TP") Adjustment - INR 2,20,48

COMMISSIONER OF INCOME TAX vs. ANKITECH PVT LTD

Bench: HON'BLE MR. JUSTICE A.K.SIKRI,HON'BLE MR. JUSTICE M.L. MEHTA

price of the goods and materials supplied in a building contract which had been entered into in two distinct and separate parts as stated above. It could not have been the contention of the revenue prior to the 46th Amendment that when the goods and materials had been supplied under a distinct and separate contract by the contractor

PCIT-1, NEW DELHI vs. BEAM GLOBAL SPIRITS & WINE (INDIA) PVT. LTD.

Bench: HON'BLE MR. JUSTICE HARISH VAIDYANATHAN SHANKAR,HON'BLE MR. JUSTICE YASHWANT VARMA

2) of section 288; Digitally Signed By:KAMLESH KUMAR Signing Date:07.03.2025 15:09:32 Signature Not Verified ITA 155/2022 & 156/2022 Page 5 of 38 (ii) "arm's length price" means a price which is applied or proposed to be applied in a transaction between persons other than associated enterprises, in uncontrolled conditions; (iii) "enterprise" means a person (including

PCIT-1, NEW DELHI vs. BEAM GLOBAL SPIRITS & WINE (INDIA)PVT.LTD.

Bench: HON'BLE MR. JUSTICE HARISH VAIDYANATHAN SHANKAR,HON'BLE MR. JUSTICE YASHWANT VARMA

2) of section 288; Digitally Signed By:KAMLESH KUMAR Signing Date:07.03.2025 15:09:32 Signature Not Verified ITA 155/2022 & 156/2022 Page 5 of 38 (ii) "arm's length price" means a price which is applied or proposed to be applied in a transaction between persons other than associated enterprises, in uncontrolled conditions; (iii) "enterprise" means a person (including

(Now known as Sony India Limited)

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 Pricing Officer/ Assessing Officer in respect of expenditure treated as AMP Expenses and if so in which circumstances? 4. If answer to question Nos.2 and 3 is in favour

LI & FUNG INDIA PVT LTD vs. COMMISSIONER OF INCOME TAX

The appeal is allowed and the order dated 25/11/11 of the ITAT Tribunal, Delhi Branch

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

transfer pricing regulations is to prevent shifting out of profits by manipulating prices charged or paid in international transactions, thereby eroding the country's tax base. The new section 92 is, therefore, no intended to be applied ITA 306/2012 Page 39 in cases where the adoption of the Arm's length Price, determined under the regulations would result

DCM SHRIIRAM LTD.,NEW DELHI vs. ADDL.CIT, SPECIAL RANGE- 3 , NEW DELHI

In the result appeal of assessee is partly allowed

Bench: Shri Kul Bharat & Shri Prashant Maharishi(Through Video Conferencing)

Section 92CA of the act. 06. As stated, that assessee mostly had Specified Domestic Transactions [SDT]. Assessee has shown transfer of power and steam from eligible unit to non-eligible unit during the year. 07. Assessee has shown the transfer of the power as per its transfer pricing study report from eligible unit to non-eligible unit as Under :- Transferor

PR. COMMISSIONER OF INCOME TAX, CENTRAL-1, DELHI vs. SMT. SANGEETA SAWHNEY

Bench: HON'BLE MR. JUSTICE VIBHU BAKHRU,HON'BLE MR. JUSTICE TEJAS KARIA

price. Expeditious nature of a remedy is concerned with the quick disposal and abhors unreasonable delays. Yet another facet of effective remedy is in its cohesiveness. 23. In conclusion, we hold that an application under Section 29A(5) for extension of the mandate of the arbitrator is maintainable even after the expiry of the time under Sections

DCIT, NEW DELHI vs. M/S. NEW DELHI TELEVISION LTD., NEW DELHI

Bench: Shri H. S. Sidhu & Shri Prashant Maharishinew Delhi Television Ltd, Vs. Acit, 207, Okhla Industrial Estate, Phase- Circle-13(1), Iii, New Delhi New Delhi Pan: Aaacn0865D (Appellant) (Respondent) Acit, Vs. New Delhi Television Ltd, Circle-13(1), 207, Okhla Industrial Estate, New Delhi Phase-Iii, New Delhi Pan: Aaacn0865D (Appellant) (Respondent)

2 of that appendix, guarantee in relation to bondholders redemption was mentioned that the parent company (appellant) undertakes to enter into, by not letter then 120 days prior to date i.e. three years after the closing date, a guarantee pursuant to which the parent company will guarantee the due and punctual payment of the outstanding amount of the bonds

M/S. NEW DELHI TELEVISION LTD.,NEW DELHI vs. ACIT, NEW DELHI

Bench: Shri H. S. Sidhu & Shri Prashant Maharishinew Delhi Television Ltd, Vs. Acit, 207, Okhla Industrial Estate, Phase- Circle-13(1), Iii, New Delhi New Delhi Pan: Aaacn0865D (Appellant) (Respondent) Acit, Vs. New Delhi Television Ltd, Circle-13(1), 207, Okhla Industrial Estate, New Delhi Phase-Iii, New Delhi Pan: Aaacn0865D (Appellant) (Respondent)

2 of that appendix, guarantee in relation to bondholders redemption was mentioned that the parent company (appellant) undertakes to enter into, by not letter then 120 days prior to date i.e. three years after the closing date, a guarantee pursuant to which the parent company will guarantee the due and punctual payment of the outstanding amount of the bonds

LIUGONG INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

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

Bench: Shri I.C. Sudhir & Shri L.P. Sahu

section 92C, the arm 's length price in relation to an international transaction shall be determined by any of the following methods, being the most appropriate method, in the following manner, namely:— (a) comparable uncontrolled price method, by which,— (i) the price charged or paid for property transferred or services provided in a comparable uncontrolled transaction, or a number

TELETUBE ELECTRONICS LTD

The appeal of the Assessee is allowed

price of the asset was fixed it was between the parties to decide about the terms of payments which unless prohibited in the statute cannot be gone behind. 15. On an examination of the lease deed, the ITAT held that the leasehold rights in the business assets were sold for Rs.20.729 crore which was undoubtedly agreed to be paid

TELETUBE ELECTRONICS LTD

The appeal of the Assessee is allowed

price of the asset was fixed it was between the parties to decide about the terms of payments which unless prohibited in the statute cannot be gone behind. 15. On an examination of the lease deed, the ITAT held that the leasehold rights in the business assets were sold for Rs.20.729 crore which was undoubtedly agreed to be paid

CIT vs. M/S TELETUBE ELECTRONICS LTD

The appeal of the Assessee is allowed

price of the asset was fixed it was between the parties to decide about the terms of payments which unless prohibited in the statute cannot be gone behind. 15. On an examination of the lease deed, the ITAT held that the leasehold rights in the business assets were sold for Rs.20.729 crore which was undoubtedly agreed to be paid

DCIT, NEW DELHI vs. M/S JSL LTD.,, HISAR

Accordingly, ground number 2 of the appeal of the learned AO for 2007 – 08 is dismissed

Bench: Smt Diva Singh & Shri Prashant Maharishi

Transfer pricing adjustment of Rs. 34,94,445 by comparing prices of international transaction of export with prices of export of steel product to unrelated party after making adjustment for variation in composition of Nickel. 3.1 That the assessing officer / TPO erred on facts and in law in not appreciating that the prices of international transaction of export of steel

JINDAL STAINLESS LTD.,HISAR vs. DCIT, NEW DELHI

Accordingly, ground number 2 of the appeal of the learned AO for 2007 – 08 is dismissed

Bench: Smt Diva Singh & Shri Prashant Maharishi

Transfer pricing adjustment of Rs. 34,94,445 by comparing prices of international transaction of export with prices of export of steel product to unrelated party after making adjustment for variation in composition of Nickel. 3.1 That the assessing officer / TPO erred on facts and in law in not appreciating that the prices of international transaction of export of steel

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

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

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)

section 92 otiose and the definition of ‗internal transaction‘ u/s 92B and rule 10B redundant. This is patently an unacceptable position having no sanction of the Indian transfer pricing law. Borrowing a contrary mandate of the TP provisions of other countries and reading it into our provisions is not permissible. The requirement under our law is to compute the income

GOODYEAR INDIA LTD.,,FARIDABAD vs. ACIT, NEW DELHI

Bench: : Shri I.C. Sudhir & Shri L.P. Sahu

transfer pricing in the case of LG Electronics India Pvt. Ltd. relied upon by the TPO in the impugned order, as erroneous and unacceptable. The Hon’ble Delhi High Court considering the dispute on facts of several 24. distributors laid down important transfer pricing principles, viz. (a) ‘Bright Line Test’ applied by the Revenue has no statutory mandate