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 92 of the Act. 44. However, in the present appeals, the very existence of an international transaction is in issue. The specific case of MSIL is that the Revenue has failed to show the existence of any agreement, understanding or arrangement between MSIL and SMC regarding the AMP spend of MSIL. It is pointed out that

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)

transfer but subscribe actual earning of profit, then impugned suggestion of AO do not have legal sanctity in eyes of law. 10.09 A very pertinent question has been raised by Id.AR Mr. Patel that what should be line of demarcation to determine sale price of a product if not market DCIT Vs. Dharampal Satyapal Ltd. price. As far as present

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

Section 133(6) of the Act to enable the Assessee I.T.A. No.1065/Del/2022 11 to place its response and defend its stance on application of MAM. It was thus submitted that ITAT, in first round, has not adjudicated the application of CUP as MAM to benchmark the impugned transactions. 11. We have heard the rival submission on the transfer pricing adjustment

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)

section 92C (2) of the Act. 11. That on facts and circumstances of the case and in law, the CIT(A) have erred in not directing the AO/TPO to use multiple years data for comparable companies as advocated by the provisions of Rule 10B(4) of the Rules for the purposes of determination of arm's length price. CORPORATE

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)

section 92C (2) of the Act. 11. That on facts and circumstances of the case and in law, the CIT(A) have erred in not directing the AO/TPO to use multiple years data for comparable companies as advocated by the provisions of Rule 10B(4) of the Rules for the purposes of determination of arm's length price. CORPORATE

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

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

section 92C (2) of the Act.\n11. That on facts and circumstances of the case and in law, the CIT(A)\nhave erred in not directing the AO/TPO to use multiple years data for\ncomparable companies as advocated by the provisions of Rule 10B(4) of\nthe Rules for the purposes of determination of arm's length price.\nCORPORATE

HEADSTRONG SERVICES INDIA PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal of the assessee stands partly allowed for statistical purposes in terms of our observations contained in the preceding paragraphs

Bench: Shri B. R. R. Kumar

transfer pricing ITA 6690/Del/2016 Assessment year 2012-13 officer/assessing officer to exclude the above comparable 39 for the similar reasons given by the Ld. dispute resolution panel for this year also." 5.5.1 On identical facts and respectfully following the order of the co-ordinate Bench in assessee's own case as above mentioned, we direct the AO/TPO

BAUSCH & LOMB EYECARE (INDIA) PVT. LTD.

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

transfer pricing adjustment in terms of Section 92 of the Act. The Assessee here has throughout been contesting the very existence of any international transaction involving AMP expenditure between the Assessee and its AE, i. e., B&L, USA. Further the Revenue has not been able to contest the submissions of Assessee that as far as the Assessee is concerned

BAUSCH & LOMB EYECARE (INDIA) PVT. LTD.

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

transfer pricing adjustment in terms of Section 92 of the Act. The Assessee here has throughout been contesting the very existence of any international transaction involving AMP expenditure between the Assessee and its AE, i. e., B&L, USA. Further the Revenue has not been able to contest the submissions of Assessee that as far as the Assessee is concerned

BAUSCH & LOMB EYECARE (INDIA) PVT. LTD.

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

transfer pricing adjustment in terms of Section 92 of the Act. The Assessee here has throughout been contesting the very existence of any international transaction involving AMP expenditure between the Assessee and its AE, i. e., B&L, USA. Further the Revenue has not been able to contest the submissions of Assessee that as far as the Assessee is concerned

BAUSCH & LOMB EYECARE (INDIA) PVT. LTD.

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

transfer pricing adjustment in terms of Section 92 of the Act. The Assessee here has throughout been contesting the very existence of any international transaction involving AMP expenditure between the Assessee and its AE, i. e., B&L, USA. Further the Revenue has not been able to contest the submissions of Assessee that as far as the Assessee is concerned

BAUSCH & LOMB EYECARE (INDIA) PVT. LTD.

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

transfer pricing adjustment in terms of Section 92 of the Act. The Assessee here has throughout been contesting the very existence of any international transaction involving AMP expenditure between the Assessee and its AE, i. e., B&L, USA. Further the Revenue has not been able to contest the submissions of Assessee that as far as the Assessee is concerned

BAUSCH & LOMB EYECARE (INDIA) PVT. LTD.

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

transfer pricing adjustment in terms of Section 92 of the Act. The Assessee here has throughout been contesting the very existence of any international transaction involving AMP expenditure between the Assessee and its AE, i. e., B&L, USA. Further the Revenue has not been able to contest the submissions of Assessee that as far as the Assessee is concerned

BAUSCH & LOMB EYECARE (INDIA) PVT. LTD.

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

transfer pricing adjustment in terms of Section 92 of the Act. The Assessee here has throughout been contesting the very existence of any international transaction involving AMP expenditure between the Assessee and its AE, i. e., B&L, USA. Further the Revenue has not been able to contest the submissions of Assessee that as far as the Assessee is concerned

DCM SHRIRAM LTD,NEW DELHI vs. ACIT, CIRCLE-7(1), NEW DELHI

49,000\n8.\nPurchase of Goods (PVC Compounds)\n5,57,003\nTotal\n38,12,22,095\n5. The TPO after examining the TP Study Report (“TPSR”)\nsubmitted by the assessee and further examined the details filed in\nITA Nos.927 & 2587/Del/2022,\n704/Del/2021, 4328 & 1495/Del/2024\nPage | 4\nresponse to the query raised by the TPO, vide its order dated\n29.10.2018 held that

DCM SHRIRAM LIMITED,DELHI vs. ASSESSMENT UNIT, DELHI

49,000\n8.\nPurchase of Goods (PVC Compounds)\n5,57,003\nTotal\n38,12,22,095\n5. The TPO after examining the TP Study Report (“TPSR”)\nsubmitted by the assessee and further examined the details filed in\nITA Nos.927 & 2587/Del/2022,\n704/Del/2021, 4328 & 1495/Del/2024\nPage | 4 \nresponse to the query raised by the TPO, vide its order dated\n29.10.2018 held that

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

49,000\n\n8.\n\nPurchase of Goods (PVC Compounds)\n\n5,57,003\n\nTotal\n\n38,12,22,095\n\n5. The TPO after examining the TP Study Report (“TPSR”)\nsubmitted by the assessee and further examined the details filed in\n\nPage | 3\n\nresponse to the query raised by the TPO, vide its order dated\n29.10.2018

DCIT, NEW DELHI vs. DCM SHRIRAM LTD, NEW DELHI

49,000\n8.\nPurchase of Goods (PVC Compounds)\n5,57,003\nTotal\n38,12,22,095\n\n5. The TPO after examining the TP Study Report (“TPSR”)\nsubmitted by the assessee and further examined the details filed in\n\nPage | 3\n\nITA Nos.927 & 2587/Del/2022,\n704/Del/2021, 4328 & 1495/Del/2024\n\nresponse to the query raised by the TPO, vide its order