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

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

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

The appeals are allowed in the above terms, but with no orders as to costs

2. Whether AMP Expenses incurred by the Assessee in India can be treated and categorized as an international transaction under 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

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

The appeals are allowed in the above terms, but with no orders as to costs

2. Whether AMP Expenses incurred by the Assessee in India can be treated and categorized as an international transaction under 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

ACIT, NEW DELHI vs. M/S. KCT PAPERS LTD., NEW DELHI

In the result, grounds raised by the revenue are dismissed

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharmaacit, Circle 5 (1) Vs. M/S. Kct Papers Limited, New Delhi. Thapar House, 124, Janpath, New Delhi – 110 001. (Pan : Aacck4937D) (Appellant) (Respondent) Assessee By : Shri Rohit Jain, Advocate Shri Deepesh Jain, Advocate Shri Tavish Verma, Advocate Revenue By : Shri Kailash Dan Ratnoo, Cit Dr Date Of Hearing : 10.09.2025 Date Of Order : 05.12.2025 O R D E R Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax (Appeals)-Viii, New Delhi [Hereinafter Referred To As ‘Ld. Cit (A)] Dated 21.03.2014For Assessment Year 2008-09. 2. Brief Facts Of The Case Are, The Assessee Company Belongs To The Thapar Group Established By Late Lala Karam Chand Thapar. There Was A Family Settlement Between The Various Constituents Of The Karam Chand Thapar Family As A Result Of Which Revenue-Organization/Restructuring Of The Group Dated 27Th April, 2001. The Re April, 2001. The Re-Organization Of The Group Companies & Trusts Organization Of The Group Companies & Trusts Was Made Into Four Groups, As Under, Each Headed By The Sons Of Late Lala Was Made Into Four Groups, As Under, Each Headed By The Sons Of Late Lala Was Made Into Four Groups, As Under, Each Headed By The Sons Of Late Lala K.C. Thapar. The Family Tree Of Karam Chand T K.C. Thapar. The Family Tree Of Karam Chand Thapar Family Is Explained As Hapar Family Is Explained As Under In The Form Of A Diagrammatic Chart: Under In The Form Of A Diagrammatic Chart:

price of share as on 31.03.2006] [Screenshot of BSE India website is attached @ page 341 of paperbook - II] 3. FMV of 98,81,296 shares of BIL as on 1.04.2006 [1*2] Rs.136,36,18,848 3. For completeness it may be highlighted that subsequently on 28.02.2008, the shares of BIL were split in the ratio of 1:5, thereby

HERO FINCORP LIMITED,NEW DELHI vs. ACIT, CIRCLE 11(1), DELHI, C.R. BUILDING

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

50,77,825\n701,99,99,985\n20\nITA No. 2542/Del/2024\n04. It is evident that the subscribers to the above-share capital were all non-\nresidents on which provisions of section 56(2)(vib) is not applicable. Hence, as\nper the submission of the assessee company and records available, the\ncontention of the assessee is found

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)

2) and 142(1) of the Act, Shri D.C.Gupta, Sr. Manager (Finance & Accounts) of the company appeared and filed details. 4. The assessee had international transactions exceeding Rs.5 crores with its associated enterprises. Hence the case was referred to the Transfer Pricing Officer under section 92CA(1) of the Act. The Transfer Pricing Officer passed order under section 92CA

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)

2) and 142(1) of the Act, Shri D.C.Gupta, Sr. Manager (Finance & Accounts) of the company appeared and filed details. 4. The assessee had international transactions exceeding Rs.5 crores with its associated enterprises. Hence the case was referred to the Transfer Pricing Officer under section 92CA(1) of the Act. The Transfer Pricing Officer passed order under section 92CA

COMMISSIONER OF INCOME TAX-IV vs. M/S. I. K. INTERNATIONAL PVT. LTD

price of the assets: ` 7,25,00,000/- Less: WDV of the assets sold: ` 2,94,59,400/- ` 4,30,40,600/-” 10. The aforesaid amount of ` 4,30,40,600/- was brought to tax as short term capital gains computed under Section 50(2) of the Act. The Assessing Officer also negatived the assessee’s claim for deduction under

VACHASPATI SHARMA,GURGAON vs. ITO WARD -4(1), GURGAON

In the result, the appeal of the assessee is dismissed

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2019-20 Vachaspati Sharma Vs Ito Village – Hayatpur Garhi Ward-4 Harsaru, Hayatpur, Gurgaon Gurgaon Pan No.Fnqps2021R (Appellant) (Respondent) Appellants By Sh. Suraj Bhan Nain, Advocate Sh. K.L. Pahwa, Advocate Respondent By Ms. Sapna Bhatia, Cit Dr Date Of Hearing: 11/09/2024 Date Of Pronouncement: 21/11/2024 Order Sh. Sudhir Kumar, Jm :

50% deduction u/s 57(iv) of the Act on gross interest received, the AO has completed the assessment order u/s 143(3) of the Act. The assessing officer has determined the total income at Rs 25682162/- by making the addition of Rs 2,39,47720/-. 4. Aggrieved the order of the assessing officer the assessee has filed the appeal before

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

section 143(2) of the Act was issued. In response to the notices, Assessee filed the requisite details. 5. The assessee has applied Transactional Net Margin Method (‘TNMM’) being most appropriate method for benchmarking international transaction of BPO Services considering itself to be tested party and operating profit to operating cost as the profit level indicator. Operating profit margin earned

HEWITT ASSOCIATES (INDIA) PVT. LTD.,GURGAON vs. ACIT, NEW DELHI

In the result, the appeal of the assesee is treated as allowed for statistical purposes

Bench: Shri R.K. Panda & Ms. Astha Chandraasstt. Year : 2007-08

transfer pricing assessment, the Ld. TPO sought information from VMF Softech Limited under section 133(6) of the Income Tax Act, 1961 (“Act”). The Ld. TPO by referring to the response received from VMF Softech Limited excluded this company from the list of final set of comparable companies on the ground that this company is predominantly engaged in outsourcing

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

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

2) and 142(1) of the Act,\nShri D.C.Gupta, Sr. Manager (Finance & Accounts) of the company appeared\nand filed details.\n4. The assessee had international transactions exceeding Rs.5 crores with its\nassociated enterprises. Hence the case was referred to the Transfer Pricing\nOfficer under section 92CA(1) of the Act. The Transfer Pricing Officer passed\norder under section 92CA

DCIT CENTRAL CIRCLE 05 , DELHI vs. DEEPAK KOTHARI , KANPUR

In the result, the appeal filed by the assessee is allowed

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI VIMAL KUMAR (Judicial Member)

50% for Rs.7.20 crores on 22.08.2016 to M/s. Adyashakti Realtors Pvt. Ltd.. On perusal of the documents submitted by the assessee, the AO observed that assessee has transferred the land under an Agreement to Sell on 28.12.2007 and determined the whole consideration amounting to Rs.7.20 crores. Further, the AO observed that assessee has claimed indexation cost in his computation

DEEPAK KATHARI,KANPUR vs. ACIT, CC-5, NEW DELHI

In the result, the appeal filed by the assessee is allowed

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI VIMAL KUMAR (Judicial Member)

50% for Rs.7.20 crores on 22.08.2016 to M/s. Adyashakti Realtors Pvt. Ltd.. On perusal of the documents submitted by the assessee, the AO observed that assessee has transferred the land under an Agreement to Sell on 28.12.2007 and determined the whole consideration amounting to Rs.7.20 crores. Further, the AO observed that assessee has claimed indexation cost in his computation

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

2% based on the fresh search undertaken by the Ld. TPO during the course of proceedings by adopting the methodology similar to that adopted by the Appellant in the transfer pricing documentation. Page 4 of 46 ITA Nos. 462 AND 2409/Del/2022 Tupperware India Private Ltd 9. That on the facts and circumstances of the case

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

2% based on the fresh search undertaken by the Ld. TPO during the course of proceedings by adopting the methodology similar to that adopted by the Appellant in the transfer pricing documentation. Page 4 of 46 ITA Nos. 462 AND 2409/Del/2022 Tupperware India Private Ltd 9. That on the facts and circumstances of the case