(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

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 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

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

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

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

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

VIJAY AGGARWAL,DELHI vs. ITO, WARD- 48(5), NEW DELHI

In the result, all the appeals of different assessees are partly allowed

Bench: : Shri Bhavnesh Saini & Shri L.P. Sahuassessment Year: 2010-11

price as claimed by the purchaser assessee-company. The Assessing Officer had not been able to establish that anything more than what had been admitted to have been paid and received had passed hands in order to invoke provisions of section 69B. As nothing had been proved to show that any other amount than admitted had been paid

MR. SANJIV NARAYAN,NEW DELHI vs. DCIT, NEW DELHI

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year 2005-06

X Rs.240/-) and this income is added to the total income of the assessee in terms of section 17(2)(iii) read with section 2(24)(iv) of the I.T. Act, 1961). 6. Before Ld. CIT (A) the appellant raised objections against validity of assumption of jurisdiction to reassess u/s 147 of the Act, besides challenging the addition on merits

MR. J.S. GUJRAL,GURGAON vs. DCIT, NEW DELHI

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year 2005-06

X Rs.240/-) and this income is added to the total income of the assessee in terms of section 17(2)(iii) read with section 2(24)(iv) of the I.T. Act, 1961). 6. Before Ld. CIT (A) the appellant raised objections against validity of assumption of jurisdiction to reassess u/s 147 of the Act, besides challenging the addition on merits

MR. KRISHNA KUMAR PANT,NEW DELHI vs. DCIT, NEW DELHI

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year 2005-06

X Rs.240/-) and this income is added to the total income of the assessee in terms of section 17(2)(iii) read with section 2(24)(iv) of the I.T. Act, 1961). 6. Before Ld. CIT (A) the appellant raised objections against validity of assumption of jurisdiction to reassess u/s 147 of the Act, besides challenging the addition on merits

MR. RANJEET SINGH,GURGAON vs. DCIT, NEW DELHI

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year 2005-06

X Rs.240/-) and this income is added to the total income of the assessee in terms of section 17(2)(iii) read with section 2(24)(iv) of the I.T. Act, 1961). 6. Before Ld. CIT (A) the appellant raised objections against validity of assumption of jurisdiction to reassess u/s 147 of the Act, besides challenging the addition on merits

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)

x. The learned authorised representative also placed heavy reliance on the direction of the learned dispute resolution panel in case of a sister concern SRF Ltd which is also placed in the paper book stating that in the identical facts and circumstances of the case the learned dispute resolution panel has held that steam has a cost and therefore

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

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)

56,690/-by relying on the ITAT decision in the assessee's own case for the AY 2006-07, ignoring the fact that the revenue is in appeal. Thus, the issue has not attained its finality. 2. On the facts and circumstances of the case and in law, the Ld.CIT (A) has erred in reducing the disallowance of software expenses

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)

56,690/-by relying on the ITAT decision in the assessee's own case for the AY 2006-07, ignoring the fact that the revenue is in appeal. Thus, the issue has not attained its finality. 2. On the facts and circumstances of the case and in law, the Ld.CIT (A) has erred in reducing the disallowance of software expenses