ARIVENT TECHNOLOGIES HOLDINGS LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal of the assessee is partly allowed

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

Section 234C of the Act. The appellant craves leave to add, amend, alter or vary, any of the aforesaid grounds of appeal before or at the time of hearing of the appeal and consider each of the grounds as without prejudice to the other grounds of appeal.” 4. The Ground of appeal No.1 raised by the assessee is general

ARICENT TECHNOLOGIES (HOLDINGS) LTD.,NEW DELHI vs. DCIT, CIRCLE- 3(1), NEW DELHI

In the result, the appeal of the assessee is partly allowed

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

Section 234C of the Act. The appellant craves leave to add, amend, alter or vary, any of the aforesaid grounds of appeal before or at the time of hearing of the appeal and consider each of the grounds as without prejudice to the other grounds of appeal.” 4. The Ground of appeal No.1 raised by the assessee is general

M/S. ARICENT TECHNOLOGIES (HOLDINGS) LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, the appeal of the assessee is partly allowed

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

Section 234C of the Act. The appellant craves leave to add, amend, alter or vary, any of the aforesaid grounds of appeal before or at the time of hearing of the appeal and consider each of the grounds as without prejudice to the other grounds of appeal.” 4. The Ground of appeal No.1 raised by the assessee is general

ARICENT TECHNOLOGIES (HOLDINGS) LTD.,NEW DELHI vs. JCIT, SPECIAL RANGE- 1 , NEW DELHI

In the result, the appeal of the assessee is partly allowed

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

Section 234C of the Act. The appellant craves leave to add, amend, alter or vary, any of the aforesaid grounds of appeal before or at the time of hearing of the appeal and consider each of the grounds as without prejudice to the other grounds of appeal.” 4. The Ground of appeal No.1 raised by the assessee is general

ADDL. CIT, SPECIAL RANGE- 1 , NEW DELHI vs. ARICENT TECHNOLOGIES (HOLDINGS) LTD., NEW DELHI

In the result, the appeal of the assessee is partly allowed

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

Section 234C of the Act. The appellant craves leave to add, amend, alter or vary, any of the aforesaid grounds of appeal before or at the time of hearing of the appeal and consider each of the grounds as without prejudice to the other grounds of appeal.” 4. The Ground of appeal No.1 raised by the assessee is general

ARICENT TECHNOLOGIES (HOLDINGS) LTD.,NEW DELHI vs. ADDL. CIT, SPECIAL RANGE- 1 , NEW DELHI

In the result, the appeal of the assessee is partly allowed

Bench: Ms. Sushma Chowla & Shri Prashant Maharishi

Section 234C of the Act. The appellant craves leave to add, amend, alter or vary, any of the aforesaid grounds of appeal before or at the time of hearing of the appeal and consider each of the grounds as without prejudice to the other grounds of appeal.” 4. The Ground of appeal No.1 raised by the assessee is general

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

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

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

transfer of steam has taken though additional grounds\n\nPage | 42\n\nof appeal be admitted and additional evidences filed in support of\nthe additional claim may deserves to be admitted in the interest of\njustice.\n\n44. On the other hand, Ld. CIT DR seriously objected the\nadmission of additional grounds as well as admission of additional\nevidences

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

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

TRL RICELAND PVT. LTD.,(FORMERLY KNOWN AS M/S TILDA RICELAND P.LTD.),NEW DELHI vs. ADDL.CIT, SPECIAL RANGE- 9, NEW DELHI

In the result, the appeal of the assessee is allowed partly for the statistical purposes

Bench: Shri O.P. Kant & Shri. K. N. Chary[Through Video Conferencing] Assessment Year: 2014-15

801,897,000 Arm’s Length Profit(C=4.66% OF B] 37,368,400 Arm’s Length Price (D= B+C) 839,265,400 Adjustment/Difference (E= D-A) 251,091,400 Price Received by Assessee in international transaction] 19,782,708 Proportion of AEs revenue to Total Revenue (G=F/A). 3.36% Adjustment

SONY INDIA PRIVATE LIMITED,NEW DELHI vs. ACIT, CIRCLE-22(2), DELHI

The appeals are allowed partly with consequence to\nfollow as per the determination of grounds as above

transfer pricing adjustment in respect of outstanding\nreceivables. In regard to this issue, it was submitted that in AY 2017-18, the\nTPO while computing the interest income for delayed receivables, has not\nrestricted the computation to assessment year under consideration. The TPO has\ncomputed the adjustment by considering interest up to the TPO's order, i.e., 31st\nJanuary

SONY INDIA PRIVATE LIMITED,NEW DELHI vs. ACIT, CIRCLE-22(2), DELHI

The appeals are allowed partly with consequence to\nfollow as per the determination of grounds as above

transfer pricing adjustment in respect of outstanding\nreceivables. In regard to this issue, it was submitted that in AY 2017-18, the\nTPO while computing the interest income for delayed receivables, has not\nrestricted the computation to assessment year under consideration. The TPO has\ncomputed the adjustment by considering interest up to the TPO's order, i.e., 31st\nJanuary

SONY INDIA PVT. LTD.,NEW DELHI vs. ACIT CIRCLE-24(1), NEW DELHI

The appeals are allowed partly with consequence to\nfollow as per the determination of grounds as above

transfer pricing adjustment in respect of outstanding\nreceivables. In regard to this issue, it was submitted that in AY 2017-18, the\nTPO while computing the interest income for delayed receivables, has not\nrestricted the computation to assessment year under consideration. The TPO has\ncomputed the adjustment by considering interest up to the TPO's order, i.e., 31st\nJanuary

M/S. GLOBAL ONE INDIA PRIVATE LIMITED,NEW DELHI vs. DCIT, NEW DELHI

Appeal are allowed

Bench: Sh. N. K. Billaiya & Ms Suchitra Kamblei.T.A No. 1980/Del/2014 (Assessment Year : 2009-10) Vs Dcit, M/S. Global One India Pvt. Ltd., Dso 601-603, 607-608, Circle – 12(1), 6Th Floor, Dlf South Court, New Delhi Saket, New Delhi – 110 017 (Pan : Aabcg 2558 B) (Respondent) (Appellant) Appellant By Shri Kanchan Kaushal, C.A. Respondent By Shri Bhuvnesh Kulshrestha, Cit - D.R. Date Of Hearing 03.12.2019 Date Of Pronouncement 10.12.2019

section 144C of the Act persuant to the directions of Learned Dispute Resolution Panel (Ld. DRP’) is bad in law and void ab-initio. 2. The final assessment order passed by the Ld. AO is barred by limitation as it has not been passed after taking into consideration the Learned Transfer Pricing Officer’s (“Ld. TPO”) order which has been

CANDOR GURGAON ONE REALTY PROJECTS PVT. LTD. (FORMERLY KNOWN AS UNITECH REALTY PROJECTS PVT. LTD.),MUMBAI vs. ADDL. CIT, RANGE- 2 , NEW DELHI

In the result, all the four items totalling

Bench: Shri Yogesh Kumar Us & Shri Brajesh Kumar Singh

transfer pricing adjustment can be made on a domestic transaction. 31. We will also like to distinguish the Mumbai Tribunal order in Firemenich Aromatics (India) Pvt. Ltd. (supra) by observing that in that case the issue was with regard to omission of sub-section (2A) of section 253 of the Act which was initially inserted by Finance Act, 2014 with

MDLR ESTATES PVT. LTD.,NEW DELHI vs. DCIT, CENTRAL CIRCLE-14, NEW DELHI

In the result, both the appeals filed by the respective assessees are partly allowed for statistical purpose

Bench: Sh. R. K. Panda & Sh. Kuldip Singhassessment Year: 2008-09

801 , the Supreme Court held, while affirming the principle laid down in Mohanbhai Pamabhai that when a partner retires from a partnership and the amount of his share in the net partnership assets after deduction of liabilities and prior charges is determined on taking accounts, there is no element of transfer of interest in the partnership assets by the retired

MDLR BUILDERS P.LTD,NEW DELHI vs. DCIT, CENTRAL CIRCLE-14, NEW DELHI

In the result, both the appeals filed by the respective assessees are partly allowed for statistical purpose

Bench: Sh. R. K. Panda & Sh. Kuldip Singhassessment Year: 2008-09

801 , the Supreme Court held, while affirming the principle laid down in Mohanbhai Pamabhai that when a partner retires from a partnership and the amount of his share in the net partnership assets after deduction of liabilities and prior charges is determined on taking accounts, there is no element of transfer of interest in the partnership assets by the retired