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 electricity from eligible unit to non-eligible unit is INR\n6.45 per KWH therefore, it was claimed that it is at ALP. The TPO\nhas obtained the rates from IEX and asked the assessee as to why\nExternal CUP method should not be applied, and sale rate of power\nshould not be taken at average price at which

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

SRF LIMITED,DELHI vs. ASSISTANT / DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 10(1), NEW DELHI, DELHI

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

prices at which power was purchased from respective State Electricity Board. 64. In a case where the assessee operates a Wind Power Mill (WPP) unit at Tamil Nadu to generate electricity primarily for consumption by its manufacturing units. During the year, the assessee had transferred the WPP units at effective rate of Rs. 6.35 p.u, based on fact that Tamil

SRF LIMITED,NEW DELHI vs. ACIT, CIRCLE-10(1), DELHI

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

prices at which power was purchased from respective State Electricity Board. 64. In a case where the assessee operates a Wind Power Mill (WPP) unit at Tamil Nadu to generate electricity primarily for consumption by its manufacturing units. During the year, the assessee had transferred the WPP units at effective rate of Rs. 6.35 p.u, based on fact that Tamil

SRF LIMITED ,DELHI vs. ACIT, CIRCLE-10(1), DELHI

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

prices at which power was purchased from respective State Electricity Board. 64. In a case where the assessee operates a Wind Power Mill (WPP) unit at Tamil Nadu to generate electricity primarily for consumption by its manufacturing units. During the year, the assessee had transferred the WPP units at effective rate of Rs. 6.35 p.u, based on fact that Tamil

K.R.PULP AND PAPERS LTD.,DELHI vs. ACIT, CENTRAL CIRCLE-19, DELHI

In the result, appeal of the assessee is partly allowed

price as defined in clause (ii) of\nSection 92F of the Act where the transfer of such goods is a\nspecified domestic transaction in Section 92BA of the Act. Both\nclause (iii) of the Explanation to Section 80A(6) as well as clause (i)\nof the Explanation to Section 801A

K R PULP AND PAPERS LTD. ,DELHI vs. DCIT CENTRAL CIRCLE-19 , DELHI

In the result, appeal of the assessee is partly allowed

price as defined in clause (ii) of\nSection 92F of the Act where the transfer of such goods is a\nspecified domestic transaction in Section 92BA of the Act. Both\nclause (iii) of the Explanation to Section 80A(6) as well as clause (i)\nof the Explanation to Section 801A

HERO MOTOCORP LIMITED,NEW DELHI vs. JCIT, NEW DELHI

In the result appeal of the assessee in ITA No

Bench: Sh. I. C. Sudhir & Shri Prashant Maharishihero Motocorp Limited, Jcit, 34, Basant Lok, Vasant Range-1, New Delhi Vs. Vihar, New Delhi Pan: Aaach0812J (Appellant) (Respondent) Dcit, M/S. Hero Moto Corp. Circle-11(1), Ltd., 34, Community Vs. New Delhi Centre, Basant Lok, Vasant Vihar, New Delhi-110057 (Appellant) (Respondent) Dcit, M/S. Hero Moto Corp. Circle-11(1), Ltd., 34, Community

Transfer Pricing Officer erred on facts and in law in computing adjustment on account of international transaction of payment of export commission, model fee and royalty without applying any of the prescribed methods. 9. That the assessing officer erred on facts and in law in disallowing under section 40(a)(ia) expenditure of Rs. 64,08,000 incurred on account

TATA STEEL LIMITED (SUCCESSOR OF ANGUL ENERGY LIMITED),DELHI vs. ASSISTANT COMMISSIONER OF INCOME-TAX, NEW DELHI

In the result, assessee’s appeal in ITA No

Bench: Ms. Madhumita Roy & Smt. Renu Jauhriassessment Year: 2020-21

Transfer Pricing Officer (TPO) under section 93CA(3) of the Income Tax Act, 1961 ('the Act') is illegal and bad in law in view of amendment to section 92BA of the Act vide Finance Act 2017. 3.1 That on the facts and circumstances of the case and in law the, the reference made

SHAHI EXPORTS PRIVATE LIMITED,NEW DELHI vs. ASSISSTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 8, DELHI, DELHI

In the result, appeal of the assessee is partly allowed

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2021-22] Shahi Exports Pvt.Ltd., Vs Acit, F-88, Okhla Industrial Area, Central Circle-8, Phase-I, New Delhi-110020. Delhi Pan-Aajcs1175L Appellant Respondent Appellant By Shri Shivam Malik, Adv. Respondent By Shri S.K.Jhadav, Cit Dr Date Of Hearing 01.04.2025 Date Of Pronouncement 27.06.2025 Order

price as defined in clause (ii) of Section 92F of the Act where the transfer of such goods is a specified domestic transaction in Section 92BA of the Act. Both clause (ii) of the Explanation to Section 80A(6) as well as clause (i) of the Explanation to Section 801A

BSC C&C JOINT VENTURE,NEW DELHI vs. DCIT, CIRCLE-61(1), NEW DELHI

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

Bench: SHRI G.S. PANNU (Vice President), SHRI ANUBHAV SHARMA (Judicial Member)

transfer pricing adjustment on account of interest on advance. The Ld. Assessing Officer, National Faceless Assessment Centre, Delhi proceeded to frame draft order under section 144C of the Act dated 25.09.2021. He computed the total income of the assessee at Rs. 30,92,31,440/- as under:- Total income as per return Rs. (-) 3,56,94,313/- Add: Adjustment

M/S. A.T. KEARNEY INDIA PRIVATE LIMITED,GURGAON vs. ITO, NEW DELHI

In the result the ground No

Bench: Smt Diva Singh & Shri Prashant Maharishiat Kearney India Private Ito, Limited, Ward-1(1), Vs. 6Th Floor, Tower-D, Global New Delhi Business Park, Gurgaon Pan:Aadca1436G (Appellant) (Respondent) At Kearney India Private Ito, Limited, Ward-1(1), Vs. 6Th Floor, Tower-D, Global New Delhi Business Park, Gurgaon Pan:Aadca1436G (Appellant) (Respondent)

Transfer Pricing Study to determine "ordinary profit" for the purpose of section 10A(7) read with section 801A(10) of the Act. 2.4. Based

M/S. A.T. KEARNEY INDIA PRIVATE LIMITED,GURGAON vs. ITO, NEW DELHI

In the result the ground No

Bench: Smt Diva Singh & Shri Prashant Maharishiat Kearney India Private Ito, Limited, Ward-1(1), Vs. 6Th Floor, Tower-D, Global New Delhi Business Park, Gurgaon Pan:Aadca1436G (Appellant) (Respondent) At Kearney India Private Ito, Limited, Ward-1(1), Vs. 6Th Floor, Tower-D, Global New Delhi Business Park, Gurgaon Pan:Aadca1436G (Appellant) (Respondent)

Transfer Pricing Study to determine "ordinary profit" for the purpose of section 10A(7) read with section 801A(10) of the Act. 2.4. Based

BSC C&C JOINT VENTURE,NEW DELHI vs. DCIT CIRCLE-61(1),, NEW DELHI

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

Bench: Shri M Balaganesh & Ms. Astha Chandraasstt. Year: 2017-18

Transfer Pricing Officer (“TPO”) who vide his order dated 29.01.2021 proposed adjustment of Rs. 1,14,41,802/- on account of interest on advance given to BSC C&C JV Nepal Ltd. The Ld. Assessing Officer, National Faceless Assessment Centre, Delhi (“FAO”) 3 proceeded to frame draft order under section 144C of the Act. He computed the total income

HERO MOTOCORP LTD.,NEW DELHI vs. DCIT, CIRCLE- 11(1), NEW DELHI

Appeal of the assessee is partly allowed for statistical purpose

Bench: Shri N. K. Billaiya & Ms Suchitra Kamble

price revisions, being an accrued liability at the time of purchase of raw materials, are recorded in the books of accounts by the assessee. At the year end, the company estimates the additional liability on account of price revision under negotiation and makes upward/downward provision, as the case may be, in relation to material supplied until

MOTHERSON SUMI SYSTEMS LIMITED,NEW DELHI vs. DCIT, NEW DELHI

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

Bench: Shri Shamim Yahya & Ms. Astha Chandraasstt. Year: 2010-11

801A or 801B read with Section 80A(4). The intention does not appear to be to deny relief under Section 10B(1) read with Section 10B(4) or to whittle down the ambit of those provisions as is sought to be suggested by Mr. Manchanda. Also, he is not right in contending that the decisions of the High Courts referred

HCL TECHNOLOGIES NORWAY AS ,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

In the result, similar grounds of appeal, in all the captioned

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

pricing report of the assessee group, iv) the business model involved in the instant case and v) the submissions made by the overseas affiliates of HCL group before tax authorities in their respective jurisdictions etc. 12. After elaborate and extensive inquiry, the AO concluded that the receipts by the assessee company from HCLT is towards services rendered by the assessee