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

801A as per the provisions of Income\nTax Act. As per the TP Study of the appellant (pages 95 to 211 of the Paper\nBook filed before me), the following transactions of power supply between\neligible units have been reported which are treated by\nthe appellant to be in arms length.\nIn its TP analysis / TP Study, the appellant

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

801A claimed\nby the appellant as indicated in the preceding discussion.\n\n16. The Tribunal, concurred with the aforesaid findings recorded\nby the CIT (A), by taking support of the decision of a Co-ordinate\nBench of the ITAT, Mumbai, in the case of West Cost Paper Mills (P.)\nLtd. v. CIT, [2014] 52 taxmann.com 268. As regards section 80IA

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

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

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

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

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 (iii) of the Explanation to Section 80A(6) as well as clause (i) of the Explanation to Section 801A(8) have been brought to the statute book by the Finance Act, 2012 with effect

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 ,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,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

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

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

3 ata and temperature of 135 degree Celsius with a heat value of 617 kcal/kg. The above steam is called as Extraction -2 (Low pressure steam) and used for various process and water heating at deaerator.The heat value from 779 kcal/Kg to 617 kcal/kg (for withdrawn amount of steam) was utilized by turbine for power generation and remaining heat

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

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

UNITEDHEALTH GROUP INFORMATION SERVICES PVT. LTD.,NEW DELHI vs. ADDL. CIT, SPECIAL RANGE- 9, NEW DELHI

Bench: Shri N.K.Billaiya & Shri Kuldip Singh

Transfer Pricing Officer- 3(3)(1), New Delhi (‘learned TPO’)/ AO has erred in making TP adjustment of INR 5,43,68,348/- instead of INR 94,36,839 as computed vide rectification order passed by the learned TPO under section 92CA(5) read with section 154 of the Act. 4. That on the facts of the case

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

JINDAL STEEL & POWER LTD.,NEW DELHI vs. PRCIT, GURUGRAM

In the result appeal of the assessee is allowed on the issue of the impugned order passed beyond the prescribed time, other issues are left open

Transfer Pricing Officer, it was incumbent upon him to pass a draft assessment order instead of passing a final assessment order dated 30.03.2019 failing which the entire assessment proceedings and all consequential proceedings are invalid, non-est and void ab initio. 5. That on the facts and circumstances of the case and in law, the impugned order passed

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)

ii. above are collectively satisfied that the iii. above is set in motion so as to determine the A T Kearney India Private Limited V ITO A Y 2005-06 & 2007-08 ITA no 510& 511 /Del/2014 Page 21 of 31 amount of reasonable profits, as determined having regard to the ALP, to be substituted with the declared profit

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)

ii. above are collectively satisfied that the iii. above is set in motion so as to determine the A T Kearney India Private Limited V ITO A Y 2005-06 & 2007-08 ITA no 510& 511 /Del/2014 Page 21 of 31 amount of reasonable profits, as determined having regard to the ALP, to be substituted with the declared profit

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

Price (“ALP”) of the International transactions entered into with its Associated Enterprises (“AE”) during the relevant AY under consideration. 3.1 The details of the international transactions entered by the assessee with its AE during the AY 2010-11 are as under:- S.No. Description of the transactions Amount (Rs.) 1 Purchase of goods 809,184,336 2 Sale of goods