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)

80 IA of the act) to other non-eligible businesses. Therefore, learned AO referred to the Additional Commissioner of Income Tax, Transfer Pricing Officer 1 (2), New Delhi, [learned Transfer Pricing Officer/TPO] to determine the arm’s-length price of the international transactions entered into by the assessee as per the provisions of Section

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

LI & FUNG INDIA PVT LTD vs. COMMISSIONER OF INCOME TAX

The appeal is allowed and the order dated 25/11/11 of the ITAT Tribunal, Delhi Branch

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

80% of the consideration received by the AE, which, in LFIL‟s opinion ought to have been considered at arm‟s length. 5. The Transfer Pricing Officer by an order dated 28.10.09 under Section

NOBLE RESOURCE & TRADING INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

The appeal is allowed with above direction

Bench: Shri Amit Shukla & Shri Prashant Maharishi

80,86,014/-, and thereby making an adjustment of Rs. 1,09,82,272/-. Noble Resources & Training India Pvt. Ltd Vs.DCIT, ITA No. 1827 & 1847/Del/2015 (Assessment Year: 2009-10 & 2010-11) 1.1. That on the facts of the case and in law, the Ld. AO has erred in stating that "The Transfer Pricing Officer, New Delhi after examination of company

NOBLE RESOURCES & TRADING INDIA PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

The appeal is allowed with above direction

Bench: Shri Amit Shukla & Shri Prashant Maharishi

80,86,014/-, and thereby making an adjustment of Rs. 1,09,82,272/-. Noble Resources & Training India Pvt. Ltd Vs.DCIT, ITA No. 1827 & 1847/Del/2015 (Assessment Year: 2009-10 & 2010-11) 1.1. That on the facts of the case and in law, the Ld. AO has erred in stating that "The Transfer Pricing Officer, New Delhi after examination of company

LIUGONG INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

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

Bench: Shri I.C. Sudhir & Shri L.P. Sahu

section 92F(ii) which defines arm's length price to mean a price "which is applied or proposed to be applied in a transaction between persons other than associated enterprises in uncontrolled conditions". Since the reference is to "price" and to "uncontrolled conditions" it implicitly brings into play the bright line test. In other words, it emphasises that where

RANBAXY LABORATORIES LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, we direct the AO to reduce the book profit u/s 115JB of the Act by the amount of reversal of the provision of Rs

Bench: Sh. I. C.Sudhir Judicialmember & Sh. Prashant Maharishia.Y.: - 2008-09 Ranbaxy Laboratories Ltd. Vs Acit 12Th Floor, Devika Tower, Range -15 6, Nehru Place New Delhi New Delhi Pan No. Aaacr0127N (Appellant) (Respondent)

Transfer Pricing (‗TP‘) documentation maintained by it in terms of section 92D of the Act read with Rule 10D of the Income-tax Rules, 1962 (‗Rules‘); not accepting the overseas Associated Enterprises (‗AEs‘) 2.2 ITA 196 Del 2013 Ranbaxy Laboratories limited V ACIT A.Y. 2008-09 Page 3 of 134 as the tested party, being the least complex

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)

section 288B of the Income Tax Act'1961. Copies of Form 15CA/CB issued by an independent chartered accountant were also placed before you. We respectfully submit that there should not be any disallowance on account of non-deduction of TDS/withholding taxes from the payments made to Intelsat Corporation, we are giving below a brief note on the same: During

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)

section 288B of the Income Tax Act'1961. Copies of Form 15CA/CB issued by an independent chartered accountant were also placed before you. We respectfully submit that there should not be any disallowance on account of non-deduction of TDS/withholding taxes from the payments made to Intelsat Corporation, we are giving below a brief note on the same: During

M/S. BG EXPLORATION & PRODUCTION INDIA LTD.,MUMBAI vs. JCIT, DEHRADUN

Bench: Shri I. C. Sudhir & Shri Prashant Maharishibg Exploration & Production Jcit, India Ltd, International Taxation, Bg House, Dehradun Vs. Lake Boulevard Road, Hiranandani Business Park, Powai, Mumbai Pan:Aaace4569K (Appellant) (Respondent) Dcit, Bg Exploration & Production International Taxation, India Ltd, Bg House, Lake Dehradun Boulevard Road, Hiranandani Vs. Business Park, Powai, Mumbai Pan: Aaace4569K (Appellant) (Respondent)

section 92CA of the Income Tax Act of Rs. 8018048/– . Assessee objected to the comparables before the Ld. Dispute Resolution Panel, however, the contention of the Assessee was B G Exploration & Production India Limited V DCIT ITA No 1170/Del/2015 DCIT V B G Exploration & Production India Limited ITA No 1581/Del/2015 AY 2010-11 rejected holding that the Ld. Transfer Pricing

COMMISSIONER OF INCOME TAX vs. M/S DELHI PRESS PATRA PRAKASHAN

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 DEL vs. DELHI PRESS PATRA PRAKASHAN

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 vs. DELHI PRESS PATRA PRAKASHAN LTD

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 vs. M/S DELHI PRESS PATRA PRAKASHAN

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