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 'adjustment'. This runs counter to legal position explained in CIT v. EKL Appliances Ltd. (2012) 345 ITR 241 (Del), which required a TPO "to examine the ‘international transaction’ as he actually finds the same.” In other words the very existence of an international transaction cannot be a matter for inference or surmise. 65. As already noticed, the decision

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 'adjustment'. This runs counter to legal position explained in CIT v. EKL Appliances Ltd. (2012) 345 ITR 241 (Del), which required a TPO "to examine the ‘international transaction’ as he actually finds the same.” In other words the very existence of an international transaction cannot be a matter for inference or surmise. 65. As already noticed, the decision

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)

section 80 IA (8) on ground that fair market value of goods transferred from silver foil division to eligible undertaking was held than that declared by appellant. Brief facts of issue are that special auditor is reported that during year under consideration silver for unit has transferred goods of INR 9 7796985 to various units including

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

price protection Rs. 39,23,45,128/- d. shop, sales, execution, remuneration Rs. 125,53,76,689/- e. trade discount on invoices Rs. 1658,73,81,046/- Total Rs. 1200,72,66,766/- 5.5 The ld TPO sought to treat the AMP expenses as an international transaction within the meaning of Section 92B of the Act. For this purposes

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

price protection Rs. 39,23,45,128/- d. shop, sales, execution, remuneration Rs. 125,53,76,689/- e. trade discount on invoices Rs. 1658,73,81,046/- Total Rs. 1200,72,66,766/- 5.5 The ld TPO sought to treat the AMP expenses as an international transaction within the meaning of Section 92B of the Act. For this purposes

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

price protection Rs. 39,23,45,128/- d. shop, sales, execution, remuneration Rs. 125,53,76,689/- e. trade discount on invoices Rs. 1658,73,81,046/- Total Rs. 1200,72,66,766/- 5.5 The ld TPO sought to treat the AMP expenses as an international transaction within the meaning of Section 92B of the Act. For this purposes

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

price protection Rs. 39,23,45,128/- d. shop, sales, execution, remuneration Rs. 125,53,76,689/- e. trade discount on invoices Rs. 1658,73,81,046/- Total Rs. 1200,72,66,766/- 5.5 The ld TPO sought to treat the AMP expenses as an international transaction within the meaning of Section 92B of the Act. For this purposes

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

price protection Rs. 39,23,45,128/- d. shop, sales, execution, remuneration Rs. 125,53,76,689/- e. trade discount on invoices Rs. 1658,73,81,046/- Total Rs. 1200,72,66,766/- 5.5 The ld TPO sought to treat the AMP expenses as an international transaction within the meaning of Section 92B of the Act. For this purposes

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

price protection Rs. 39,23,45,128/- d. shop, sales, execution, remuneration Rs. 125,53,76,689/- e. trade discount on invoices Rs. 1658,73,81,046/- Total Rs. 1200,72,66,766/- 5.5 The ld TPO sought to treat the AMP expenses as an international transaction within the meaning of Section 92B of the Act. For this purposes

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

price protection Rs. 39,23,45,128/- d. shop, sales, execution, remuneration Rs. 125,53,76,689/- e. trade discount on invoices Rs. 1658,73,81,046/- Total Rs. 1200,72,66,766/- 5.5 The ld TPO sought to treat the AMP expenses as an international transaction within the meaning of Section 92B of the Act. For this purposes

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

price protection Rs. 39,23,45,128/- d. shop, sales, execution, remuneration Rs. 125,53,76,689/- e. trade discount on invoices Rs. 1658,73,81,046/- Total Rs. 1200,72,66,766/- 5.5 The ld TPO sought to treat the AMP expenses as an international transaction within the meaning of Section 92B of the Act. For this purposes

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

price protection Rs. 39,23,45,128/- d. shop, sales, execution, remuneration Rs. 125,53,76,689/- e. trade discount on invoices Rs. 1658,73,81,046/- Total Rs. 1200,72,66,766/- 5.5 The ld TPO sought to treat the AMP expenses as an international transaction within the meaning of Section 92B of the Act. For this purposes

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.

73,89,174 Total 68,39,40,825 5. Aggrieved assessee filed objections before the DRP and raised various objections. With regard to objections relating to adjustment in respect of transfer of specified assets, ld. DRP observed as under :- “3.2.2 The Panel has considered the submission, which is only a reiteration of the submission before the TPO and which

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)

section 92C (2) of the Act. 11. That on facts and circumstances of the case and in law, the CIT(A) have erred in not directing the AO/TPO to use multiple years data for comparable companies as advocated by the provisions of Rule 10B(4) of the Rules for the purposes of determination of arm's length price. CORPORATE

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)

section 92C (2) of the Act. 11. That on facts and circumstances of the case and in law, the CIT(A) have erred in not directing the AO/TPO to use multiple years data for comparable companies as advocated by the provisions of Rule 10B(4) of the Rules for the purposes of determination of arm's length price. CORPORATE

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

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

section 92C (2) of the Act.\n11. That on facts and circumstances of the case and in law, the CIT(A)\nhave erred in not directing the AO/TPO to use multiple years data for\ncomparable companies as advocated by the provisions of Rule 10B(4) of\nthe Rules for the purposes of determination of arm's length price.\nCORPORATE

SUCON INDIA LTD.,FARIDABAD vs. DCIT, CIRCLE- II, FARIDABAD

In the result, appeal by the assessee stands allowed

prices or rates, a credit rating or credit index, or similar variable (sometimes called the 'underlying); (b) that requires no initial net investment or little initial net investment relative to other types of contracts that have a similar response to changes in market conditions; and (c) that is settled at a future date. Actually, derivatives are assets, whose values

DCM SHRIRAM LIMITED,DELHI vs. ASSESSMENT UNIT, DELHI

transfer of steam has taken though additional grounds\nITA Nos.927 & 2587/Del/2022,\n704/Del/2021, 4328 & 1495/Del/2024\nPage | 42 \nof appeal be admitted and additional evidences filed in support of\nthe additional claim may deserves to be admitted in the interest of\njustice.\n44. On the other hand, Ld. CIT DR seriously objected the\nadmission of additional grounds as well as admission