MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

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

transfer pricing. Likewise, payments for use of patents or copyrights are separately assessed. What the present appeals are concerned with is only the AMP expenditure incurred and nothing more. As pointed out by the Revenue the issue is not about the expenditure incurred by MSIL in engaging Indian third parties for AMP but the extent to which the AMP spend

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)

transferred to various units including the units eligible for deduction u/s 80 IB/80 IC of the act based upon the sales ratio of all manufacturing units. 4. During assessment year 2005 – 06 to 2011 – 12 assessment orders were passed under the provisions of Section 153A/143 (3) of the act based upon search and seizure operations carried out under the provisions

LG ELECTRONICS INDIA PVT. LTD.,NEW DELHI vs. ADDL. CIT, SPECIAL RANGE- 5, NEW DELHI

In the result, the appeal of the revenue in ITA No

Bench: Shri Mahavir Singh & Shri M. Balaganesh

transfer pricing adjustment of Rs. 809,06,65,961/- on account of alleged brand building activity undertaken by the assessee for the AE as under:- Computation of TP adjustment Rs. Value of sales 1,25,64,10,00,000 AMP/Sales of the comparables 3.69% Amount that represents bright line 4,636,152,900 Expenditure on AMP by assessee

M/S LG ELECTRONICS INDIA PVT. LTD.,,NEW DELHI vs. DCIT, NOIDA

In the result, the appeal of the revenue in ITA No

Bench: Shri Mahavir Singh & Shri M. Balaganesh

transfer pricing adjustment of Rs. 809,06,65,961/- on account of alleged brand building activity undertaken by the assessee for the AE as under:- Computation of TP adjustment Rs. Value of sales 1,25,64,10,00,000 AMP/Sales of the comparables 3.69% Amount that represents bright line 4,636,152,900 Expenditure on AMP by assessee

DCIT, NOIDA vs. M/S. L.G. ELECTRONICS INDIA PVT. LTD., GREATER NOIDA

In the result, the appeal of the revenue in ITA No

Bench: Shri Mahavir Singh & Shri M. Balaganesh

transfer pricing adjustment of Rs. 809,06,65,961/- on account of alleged brand building activity undertaken by the assessee for the AE as under:- Computation of TP adjustment Rs. Value of sales 1,25,64,10,00,000 AMP/Sales of the comparables 3.69% Amount that represents bright line 4,636,152,900 Expenditure on AMP by assessee

DCIT, CIRCLE-13(1), NEW DELHI vs. LG ELECTRONICS INDIA PVT. LTD., DELHI

In the result, the appeal of the revenue in ITA No

Bench: Shri Mahavir Singh & Shri M. Balaganesh

transfer pricing adjustment of Rs. 809,06,65,961/- on account of alleged brand building activity undertaken by the assessee for the AE as under:- Computation of TP adjustment Rs. Value of sales 1,25,64,10,00,000 AMP/Sales of the comparables 3.69% Amount that represents bright line 4,636,152,900 Expenditure on AMP by assessee

DCIT, CIRCLE-15(2), NEW DELHI vs. LG ELECTRONICS INDIA PVT. LTD., NEW DELHI

In the result, the appeal of the revenue in ITA No

Bench: Shri Mahavir Singh & Shri M. Balaganesh

transfer pricing adjustment of Rs. 809,06,65,961/- on account of alleged brand building activity undertaken by the assessee for the AE as under:- Computation of TP adjustment Rs. Value of sales 1,25,64,10,00,000 AMP/Sales of the comparables 3.69% Amount that represents bright line 4,636,152,900 Expenditure on AMP by assessee

LG ELECTRONICS INDIA PRIVATE LIMITED ,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

In the result, the appeal of the revenue in ITA No

Bench: Shri Mahavir Singh & Shri M. Balaganesh

transfer pricing adjustment of Rs. 809,06,65,961/- on account of alleged brand building activity undertaken by the assessee for the AE as under:- Computation of TP adjustment Rs. Value of sales 1,25,64,10,00,000 AMP/Sales of the comparables 3.69% Amount that represents bright line 4,636,152,900 Expenditure on AMP by assessee

LG ELECTRONICS INDIA PVT. LTD.,NEW DELHI vs. ADDL. CIT, SPECIAL RANGE- 5, NEW DELHI

In the result, the appeal of the revenue in ITA No

Bench: Shri Mahavir Singh & Shri M. Balaganesh

transfer pricing adjustment of Rs. 809,06,65,961/- on account of alleged brand building activity undertaken by the assessee for the AE as under:- Computation of TP adjustment Rs. Value of sales 1,25,64,10,00,000 AMP/Sales of the comparables 3.69% Amount that represents bright line 4,636,152,900 Expenditure on AMP by assessee

LG ELECTRONICS INDIA PRIVATE LIMITED,MATHURA ROAD, NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

In the result, the appeal of the revenue in ITA No

Bench: Shri Mahavir Singh & Shri M. Balaganesh

transfer pricing adjustment of Rs. 809,06,65,961/- on account of alleged brand building activity undertaken by the assessee for the AE as under:- Computation of TP adjustment Rs. Value of sales 1,25,64,10,00,000 AMP/Sales of the comparables 3.69% Amount that represents bright line 4,636,152,900 Expenditure on AMP by assessee

LG ELECTRONICS INDIA PVT. LTD.,NEW DELHI vs. DCIT, CIRCLE-15(2), NEW DELHI

In the result, the appeal of the revenue in ITA No

Bench: Shri Mahavir Singh & Shri M. Balaganesh

transfer pricing adjustment of Rs. 809,06,65,961/- on account of alleged brand building activity undertaken by the assessee for the AE as under:- Computation of TP adjustment Rs. Value of sales 1,25,64,10,00,000 AMP/Sales of the comparables 3.69% Amount that represents bright line 4,636,152,900 Expenditure on AMP by assessee

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

transfer pricing assessment proceedings, thereby, violating the principles of natural justice. 1.7 That on the facts and circumstances of the case and in law and without prejudice to any other ground, the Hon’ble DRP and Ld. AO/TPO erred in using non-comparable guarantee rates from the data obtained under Section 133(6) of the Act, thereby, resorting to cherry

ECOENERGY INSIGHTS LTD ( FORMERLY KNOWN AS CHUBB ALBA CONTROL SYSTEMS P.LTD),NEW DELHI vs. DCIT, CIRCLE-4(2), NEW DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaecoenergy Insights Ltd., Vs. Dcit, (Formerly Known As Chubb Alba Control Circle 4 (2), Systems P. Ltd.), New Delhi. Ground Floor, 18, Netaji Subhash Marg, Daryaganj, New Delhi – 110 002. (Pan :Aaaca0031C) (Appellant) (Respondent) Assessee By : Shri Nageshwar Rao, Advocate Shri Parth, Advocate Shri Pratik Rath, Advocate Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 12.08.2025 Date Of Order : 10.11.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Assessment Order Dated 25.07.2022Passed By The Assessment Unit, Income Tax Department Under Section 147 Read With Section 144C(13) R.W.S. 144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Ay 2018-19 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act.

section 92CA. Consequently, the reference appears to be invalid, and the transfer pricing and subsequent proceedings also appear to be time barred. In this context it is necessary to make following submissions – (a) time barring being a mandate to the forum, Hon’ble Tribunal may have to decide this preliminary aspect (b) assuming time barring aspect is decided in favour

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)

Transfer Pricing Officer passed order under section 92CA(3) on 22-02-2006 wherein he determined an adjustment of Rs.2,23,96,778/- to be made to the value of international transactions entered into by the assessee. Hence, a sum of Rs.2,23,96,778/- is reduced from the loss shown by the assessee. 5. The assessee has claimed

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)

Transfer Pricing Officer passed order under section 92CA(3) on 22-02-2006 wherein he determined an adjustment of Rs.2,23,96,778/- to be made to the value of international transactions entered into by the assessee. Hence, a sum of Rs.2,23,96,778/- is reduced from the loss shown by the assessee. 5. The assessee has claimed

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

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

Transfer Pricing Officer passed\norder under section 92CA(3) on 22-02-2006 wherein he determined an\nadjustment of Rs.2,23,96,778/- to be made to the value of international\ntransactions entered into by the assessee. Hence, a sum of Rs.2,23,96,778/- is\nreduced from the loss shown by the assessee.\n5. The assessee has claimed

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

Price in the international transaction. Accordingly we allow the Grounds of Appeal No.9. 51. The Grounds of Appeal No. 10 to12 have not been pressed by the Ld. Counsel for the Assessee as the same are academic in nature, therefore the said grounds are not adjudicated. 52. In so far as Grounds No. 13 and 14 are concerned

BAUSCH & LOMB EYECARE (INDIA) PVT. LTD.

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

transfer pricing adjustment envisages the substitution of the price of such international transaction with the ALP. 54. Under Sections 92B to 92F, the pre-requisite for commencing the TP exercise is to show the existence of an international transaction. The next step is to determine the price of such transaction. The third step would be to determine