COMMISSIONER OF INCOME TAX

80-IA. - Deduction in respect of profits and gains from industrial undertakings, etc., in certain cases.- (1) Where the gross total income of an assessee includes any profits and gains derived from any business of an industrial undertaking or a hotel or operation of a ship or developing, maintaining and operating any infrastructure facility…………. to which this section applies, there

COMMISSIONER OF INCOME TAX

80-IA. - Deduction in respect of profits and gains from industrial undertakings, etc., in certain cases.- (1) Where the gross total income of an assessee includes any profits and gains derived from any business of an industrial undertaking or a hotel or operation of a ship or developing, maintaining and operating any infrastructure facility…………. to which this section applies, there

COMMISSIONER OF INCOME TAX

80-IA. - Deduction in respect of profits and gains from industrial undertakings, etc., in certain cases.- (1) Where the gross total income of an assessee includes any profits and gains derived from any business of an industrial undertaking or a hotel or operation of a ship or developing, maintaining and operating any infrastructure facility…………. to which this section applies, there

COMMISSIONER OF INCOME TAX

80-IA. - Deduction in respect of profits and gains from industrial undertakings, etc., in certain cases.- (1) Where the gross total income of an assessee includes any profits and gains derived from any business of an industrial undertaking or a hotel or operation of a ship or developing, maintaining and operating any infrastructure facility…………. to which this section applies, there

COMMISSIONER OF INCOME TAX

80-IA. - Deduction in respect of profits and gains from industrial undertakings, etc., in certain cases.- (1) Where the gross total income of an assessee includes any profits and gains derived from any business of an industrial undertaking or a hotel or operation of a ship or developing, maintaining and operating any infrastructure facility…………. to which this section applies, there

DCIT, CC-29, NEW DELHI vs. DHARAMPAL SATYAPAL LTD., NEW DELHI

Bench: Shri G. S. Pannu & Shri Yogesh Kumar U.S.I.T.A. No. 1976/Del/2020 (A.Y 2013-14)

transferred from one undertaking to another undertaking without determination of market price of such goods, is not the mandate of provisions of section 80

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

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

Section 92C may not only be legally impermissible but will lend itself to arbitrariness. What is then needed is a clear statutory scheme encapsulating the legislative policy and mandate which provides the necessary checks against arbitrariness while at the same time addressing the apprehension of tax avoidance. 76. As explained by the Supreme Court in CIT v. B.C. Srinivasa Setty

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

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

Section 92C may not only be legally impermissible but will lend itself to arbitrariness. What is then needed is a clear statutory scheme encapsulating the legislative policy and mandate which provides the necessary checks against arbitrariness while at the same time addressing the apprehension of tax avoidance. 76. As explained by the Supreme Court in CIT v. B.C. Srinivasa Setty

DCM SHRIRAM INDUSTRIS LTD,NEW DELHI vs. DCIT CIRCLE-7(1), NEW DELHI

In the result, the appeal filed by the assessee is allowed in above terms

Bench: Shri Challa Nagemdra Prasad & Shri S. Rifaur Rahman

section 92CA of the Act was made to the TPO for determination of ALP in respect of specified domestic transactions. Certain transfer pricing adjustment as well non-transfer pricing additions were made in the final assessment order, which are agitated by the appellant before us in the following concise grounds of appeal. “1. The Ld. AO has erred

DCM SHRIRAM LIMITED,DELHI vs. ASSESSMENT UNIT, DELHI

section 80 IA on the transfer price charged by the\neligible units to non-eligible units was held as allowable

DCM SHRIRAM LTD,NEW DELHI vs. ACIT, CIRCLE-7(1), NEW DELHI

section 80 IA on the transfer price charged by the\neligible units to non-eligible units was held as allowable

DCM SHRIIRAM LIMITED,NEW DELHI vs. NEAC, NEW DELHI

section 80 IA on the transfer price charged by the\neligible units to non-eligible units was held as allowable

DCIT, NEW DELHI vs. DCM SHRIRAM LTD, NEW DELHI

section 80 IA on the transfer price charged by the\neligible units to non-eligible units was held as allowable

ADOBE SYSTEMS SOFTWARE IRELAND LIMITED,IRELAND vs. ACIT CIRCLE 1(1)(1) INTERNATIONAL TAXATION, NEW DELHI

In the result, the appeal of the assessee is treated as allowed for statistical purposes subject to the directions contained in para 11, 18 and 19 above

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2020-21

80,35,328/-. Other receipts viz. receipts from software supply and automated services are claimed non-taxable in India by the assessee. The case of the assessee was not referred to the Ld. Transfer Pricing Officer (“TPO”) by the Ld. AO in view of the fact that the transaction entered by the assessee with Adobe Systems India Pvt. Ltd. (“Adobe

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

80,965/- c. 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

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

80,965/- c. 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

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

80,965/- c. 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

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

80,965/- c. 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