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

3. Inter\nUnit transfer cost Rs.473.59 Cost of a utility determined as per para\n5.3.2 plus share of administrative overhead to be charged.”\n\n40. Therefore, from the above analysis it is apparent that the learned\nrevenue authorities have incorrectly held that there is no cost of production\nof steam.\n\n41. Even otherwise steam is a commercially viable product

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

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

In the result, appeal of the assessee is partly allowed

801A(8) have been brought to the\nstatute book by the Finance Act, 2012 with effect from 1st April\n2013.\n\n21. Now coming to the facts of the present case where the TPO\nhad evaluated and compared the transactions with reference to the\naverage price of IEX. The power generating companies, who did not\nsell the electricity

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. DCIT CENTRAL CIRCLE-19 , DELHI

In the result, appeal of the assessee is partly allowed

801A(8) have been brought to the\nstatute book by the Finance Act, 2012 with effect from 1st April\n2013.\n21. Now coming to the facts of the present case where the TPO\nhad evaluated and compared the transactions with reference to the\naverage price of IEX. The power generating companies, who did not\nsell the electricity in the open

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

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

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

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

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

3,18,97,42,955/- by making adjustment towards reduction in assessee’s claim of deduction u/s 80IA of the Act as per TPO’s order. 5. Against such order, the present appeal filed by the assessee before Tribunal. 6. In Ground No.1, the assessee has challenged the action of AO/TPO/DRP in reduction the claim of deduction

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

801A(10) of the Income Tax Act, 1961. 7. The Ld. CIT (A) has erred on facts and in law, giving the opinion that the Assessing Officer was wrong in apportioning the AMP expenses amongst the assessee and its two sisterly concerns, since the assessee is a marketing entity while the latter two are purely manufacturing concerns without considering

DCIT, CENTRAL CIRCLE-20, DELHI vs. LOTUS HERBALS PVT. LTD, DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

801A(10) of the Income Tax Act, 1961. 7. The Ld. CIT (A) has erred on facts and in law, giving the opinion that the Assessing Officer was wrong in apportioning the AMP expenses amongst the assessee and its two sisterly concerns, since the assessee is a marketing entity while the latter two are purely manufacturing concerns without considering

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

801A(10) of the Income Tax Act, 1961. 7. The Ld. CIT (A) has erred on facts and in law, giving the opinion that the Assessing Officer was wrong in apportioning the AMP expenses amongst the assessee and its two sisterly concerns, since the assessee is a marketing entity while the latter two are purely manufacturing concerns without considering

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

801A(10) of the Income Tax Act, 1961. 7. The Ld. CIT (A) has erred on facts and in law, giving the opinion that the Assessing Officer was wrong in apportioning the AMP expenses amongst the assessee and its two sisterly concerns, since the assessee is a marketing entity while the latter two are purely manufacturing concerns without considering

DCIT, CENTRAL CIRCLE-20, NEW DELHI vs. LOTUS HERBALS P.LTD, DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

801A(10) of the Income Tax Act, 1961. 7. The Ld. CIT (A) has erred on facts and in law, giving the opinion that the Assessing Officer was wrong in apportioning the AMP expenses amongst the assessee and its two sisterly concerns, since the assessee is a marketing entity while the latter two are purely manufacturing concerns without considering

COSMIC INFORMATICS PVT. LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE - 2, NEW DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

801A(10) of the Income Tax Act, 1961. 7. The Ld. CIT (A) has erred on facts and in law, giving the opinion that the Assessing Officer was wrong in apportioning the AMP expenses amongst the assessee and its two sisterly concerns, since the assessee is a marketing entity while the latter two are purely manufacturing concerns without considering