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 234D of the Act.” 47. For assessment year 2007 – 08, the learned transfer pricing officer considered the reimbursement of INR 45,100,000 as part of the cost base of the assessee and therefore determined the profit level indicator of the assessee at (-) 13.98% whereas the PLI of the comparables was determined at 13.04% and thus worked

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)

Sections (1) and (2) to Section 92C are applicable to the assessed, as well as the Assessing Officer invoking power under Sub-Section (3) to Section 92C of the Act. As noted above, sub-section (2) to Section 92C stipulates that most appropriate method, out of the methods specified in sub-section (1) shall be applied to determine

COMMISSIONER OF INCOME TAX vs. MENTOR GRAPHICS (NOIDA) PVT.LTD

The appeal is allowed

2) of section 92C on the basis of such material or informaction or document available with him. After the Transfer Pricing Officer determines the arm’s length price, it is incumbent upon him to send a copy of the order to the assessing officer and to the assessee. In the present case what has happened is that the Transfer Pricing

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)

transfer-pricing officer. iii. With respect to the disallowance u/s 14 A of the act, the learned DRP directed the learned assessing officer to compute the indirect interest expenditure Under rule 8D (2) (ii) of the act only with respect to the dividend bearing investment and further for the purpose of rule 8D (2) (iii) the disallowance made

DCIT, CIRCLE- 16(2), NEW DELHI vs. MENETA AUTOMOTIVE COMPONENTS PVT. LTD., NEW DELHI

In the result, the appeal of the Revenue is dismissed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

section (2) thereof. There may be occasions where application of the most appropriate method provides results which are different but equally reliable. In all such cases, further scrutiny may be necessary to evaluate the appropriateness of the method, the correctness of the data, weight given to various factors and so on. The selection of the most appropriate method will depend

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

2) or information and documents relating to the international transaction have not been kept and are maintained by the assessee in accordance with the provisions contained in sub section (1) of section 92D of the Income-tax Act and the rules made there under; or the information or data used in computation of the Arms length price is not reliable

CIT vs. CUSHMAN AND WAKEFIELD INDIA PVT LTD

The appeal is partly allowed

2 3.63% 165523 9 6.3% 7659 4430 120 89 4.3 47.926 C& W Asia 36844 97 100 % 262736 33 100% 2109 49 70316 281 265 100 % 517.083 31. As explained, for 82.44% share of the revenue from the services of the Client Solution Group, the relatable cost allocation was 72.5%. The precise activities conducted by the Client Solutions Group

CIT vs. M/S TELETUBE ELECTRONICS LTD

The appeal of the Assessee is allowed

2 (47) of the Act. The meaning of transfer in Section 269UA(f) has to be restricted for the purposes of Chapter XXC. The ITAT also held that merely because the payment of instalment was shown as lease rental, it could not be said that the instalments paid did not form part of the price. Once the price

TELETUBE ELECTRONICS LTD

The appeal of the Assessee is allowed

2 (47) of the Act. The meaning of transfer in Section 269UA(f) has to be restricted for the purposes of Chapter XXC. The ITAT also held that merely because the payment of instalment was shown as lease rental, it could not be said that the instalments paid did not form part of the price. Once the price

TELETUBE ELECTRONICS LTD

The appeal of the Assessee is allowed

2 (47) of the Act. The meaning of transfer in Section 269UA(f) has to be restricted for the purposes of Chapter XXC. The ITAT also held that merely because the payment of instalment was shown as lease rental, it could not be said that the instalments paid did not form part of the price. Once the price

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

M/S ATOTECH INDIA LTD.,,GURGAON vs. ACIT, GURGAON

In the result ground No. 1 of the appeal of the assessee with respect to the above issue is allowed with above direction

Bench: I.C.Sudhir & Shri Prashant Maharishi & Atotech India Ltd, Acit, 66, Km Stone, Nh-8, Gurgaon Circle, Vs. Delhi Jaipur Highway, Gurgaon Gurgaon Pan:Aaccm0338G (Appellant) (Respondent)

2 of the appeal of the assessee is set aside to the file of the Ld. transfer pricing officer. 18. Ground No. 3 of the appeal of the assessee is against the confirmation of the addition of Rs. 30175982/- made by the Ld. transfer pricing officer and confirmed by the Ld. CIT (A). 19. The Ld. authorized representative submitted that

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

COMMISSIONER OF INCOME TAX vs. ECE INDUSTRIES LTD.

Bench: HON'BLE MR. JUSTICE A.K.SIKRI,HON'BLE MR. JUSTICE SURESH KUMAR KAIT

transferred to M/s. Osram India (P) Ltd. It was contended that no part of the price of `42.50 Crores was attributable to any particular asset including any depreciable asset and therefore provisions of Section 50(2

Commissioner of Income Tax vs. ECE Industries Limited

transferred to M/s. Osram India (P) Ltd. It was contended that no part of the price of `42.50 Crores was attributable to any particular asset including any depreciable asset and therefore provisions of Section 50(2