MAHAVIR TRANSMISSION LTD,NEW DELHI vs. DCIT, CENTRAL CIRCLE-25, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

56(2)(x). On the other hand, the ld. DR supported the order of authorities below. The ld. DR argued that reference to DVO is compulsory but the option of the Assessing Officer. 82. Heard the arguments of both the parties and perused the material available on record. 83. The provisions of Section 50C are as under: “Special provision

MAHAVIR TRANSMISSION LTD,NEW DELHI vs. DCIT, CENTRAL CORCLE-25, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

56(2)(x). On the other hand, the ld. DR supported the order of authorities below. The ld. DR argued that reference to DVO is compulsory but the option of the Assessing Officer. 82. Heard the arguments of both the parties and perused the material available on record. 83. The provisions of Section 50C are as under: “Special provision

DCIT, CENTRAL CIRCLE-25, NEW DELHI vs. MAHAVEER TRANSMISSION LTD, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

56(2)(x). On the other hand, the ld. DR supported the order of authorities below. The ld. DR argued that reference to DVO is compulsory but the option of the Assessing Officer. 82. Heard the arguments of both the parties and perused the material available on record. 83. The provisions of Section 50C are as under: “Special provision

MAHAVIR TRANSMISSION LTD,NEW DELHI vs. DCIT, CENTRAL CIRCLE-25, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

56(2)(x). On the other hand, the ld. DR supported the order of authorities below. The ld. DR argued that reference to DVO is compulsory but the option of the Assessing Officer. 82. Heard the arguments of both the parties and perused the material available on record. 83. The provisions of Section 50C are as under: “Special provision

DCIT, CENTRAL CIRCLE-25, NEW DELHI vs. MAHAVEER TRANSMISSION LTD, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

56(2)(x). On the other hand, the ld. DR supported the order of authorities below. The ld. DR argued that reference to DVO is compulsory but the option of the Assessing Officer. 82. Heard the arguments of both the parties and perused the material available on record. 83. The provisions of Section 50C are as under: “Special provision

MAHAVIR TRANSMISSIN LTD ,NEW DELHI vs. DCIT, CENTRAL CIRCLE-25 , NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

56(2)(x). On the other hand, the ld. DR supported the order of authorities below. The ld. DR argued that reference to DVO is compulsory but the option of the Assessing Officer. 82. Heard the arguments of both the parties and perused the material available on record. 83. The provisions of Section 50C are as under: “Special provision

DCIT, CENTRAL CIRCLE-25, NEW DELHI vs. MAHAVEER TRANSMISSION LTD., NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

56(2)(x). On the other hand, the ld. DR supported the order of authorities below. The ld. DR argued that reference to DVO is compulsory but the option of the Assessing Officer. 82. Heard the arguments of both the parties and perused the material available on record. 83. The provisions of Section 50C are as under: “Special provision

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

MANKIND PHARMA LIMITED,DELHI vs. DCIT, CIRCLE-1(1)(1), MEERUT

In the result, the additional Ground No

Bench: Shri Challa Nagendra Prasad & Shri Pradip Kumar Kedia

X 3 6 ” 4 2 0 6 & G e n e r a l Ma r t 37. On being inquired by the bench, the ld. counsel strenously took 27 I.T.A. No.2313/Del/2022 us through the various items of purchase and corresponding purchases from unrelated entities or such purchases made by AEs etc. to demonstrate that the supply rate

ABHIRVEY PROJECTS PRIVATE LIMITED,NEW DELHI vs. ACIT CIRCLE-1(2), NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Challa Nagendra Prasad & Shri Pradip Kumar Kedia

transfer agent, investments, consultants, stocks, shares and securities of all kind of description. During the previous year relevant for the assessment year 2014-15, the assessee had allotted 3,15,000 Equity shares of face value of Rs. 10/- each at a premium of Rs. 40/- per share consisting total amount of Rs. 1,26,00,000/-. The said allotment

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:

x) Long Term Capital gains as per A.O. = G) - (E) = Rs. 49,40,64,8001- (-) Rs. 11,20,12,407/- = Rs.38,20,52,393/- 12. Thus, the main issue for consideration is adoption of cost of acquisition of shares in computing the capital gains on sale thereof. The assessee has adopted indexed cost of acquisition with reference to the period

ITO WARD - 23(1), NEW DELHI vs. SHRADHA MH ONE TV NETWORK PVT LTD, NEW DELHI

In the result, appeal of the Revenue is dismissed

Bench: Shri Anil Chaturvedi & Ms. Astha Chandra

x Rs.22,765.42 each]. The A.O. was of the view that since the assessee had introduced share capital during the year under consideration, provisions of Section 56(2)(viib) is applicable to the issuance of shares. He thereafter rejected the valuation report wherein the shares were valued on the basis of DCF method and thereafter on the basis

THINKSTATIONS LEARNING PRIVATE LIMITED,NEW DELHI vs. ACIT CIRCLE-25(1), NEW DELHI

In the result, both the appeals of the assessee are allowed

Bench: Shri Narendra Kumar Billaiya & Shri Challa Nagendra Prasad

price. The Assessing Officer 2 ITA. Nos. 9824 & 7345/Del/2019 referring to the provisions of section 56(2)(viib) and the explanation he was of the view that assessee has to consider the valuation whichever is higher between (i) the valuation according to Rule 11UA of Income Tax Rules or (ii) the value of shares to the satisfaction of the Assessing

THINKSTATIONS LEARNING PRIVATE LIMITED,NEW DELHI vs. ACIT CIRCLE-8(1), NEW DELHI

In the result, both the appeals of the assessee are allowed

Bench: Shri Narendra Kumar Billaiya & Shri Challa Nagendra Prasad

price. The Assessing Officer 2 ITA. Nos. 9824 & 7345/Del/2019 referring to the provisions of section 56(2)(viib) and the explanation he was of the view that assessee has to consider the valuation whichever is higher between (i) the valuation according to Rule 11UA of Income Tax Rules or (ii) the value of shares to the satisfaction of the Assessing

BRAWNY NIVESH P.LTD,NEW DELHI vs. ACIT, CENTRAL CIRCLE-13, NEW DELHI

In the result, appeal of the assessee is partly allowed

Bench: Shri Mahavir Singh & Shri Brajesh Kumar Singh

transfer under clause (via) or clause (vic) or clause (vicb) or clause (vid) or clause (vii) of section 47.” 2.3. In light of the above provisions and to find out whether the transaction was covered in point no. (iii) above or not, the AO noted that the Fair Market Value (FMV) of shares of Gain E Commerce

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

56,39,878/- to Rs. 1,30,50,397/-. The Final Assessment Order (Order impugned in the present Appeal) came to be passed on 25-11-2016 by computing the income as follows: Particulars Amount (In Rs.) Income as per ITR 74,47,41,550/- Additions 1. Addition on account of transfer pricing 1,30,50,397/- adjustment Total Income

ACIT CIRCLE-10(1), NEW DELHI vs. GAMMA PIZZAKRAFT (OVERSEAS) PVT LTD, NEW DELHI

In the result, the appeal of the Revenue is dismissed

Bench: Sh. C. M. Gargdr. B. R. R. Kumar

price for the shares. 6 Gamma Pizzakraft (Overseas) Pvt. Ltd. h) The assessee submitted that certain general statement of the valuer could not be a basis for making additions. 11. It is a fact on record that the assessee made further submissions on 07.12.2018 vide letter dated 06.12.2018. The AO refused to accept the said letter on 07.12.2018. The assessee