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

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

price of steam at cost.\nThis order has been accepted by the revenue and no further appeal has\nbeen filed. Therefore this issue becomes final with respect to the\ndetermination of ALP of transfer of steam at cost by the eligible unit to non\neligible unit.\n\n44. Further Honourable Gujarat High court in Principal Commissioner of\nIncome

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

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

4\nresponse to the query raised by the TPO, vide its order dated\n29.10.2018 held that the international transactions carried out by\nthe assessee company are at Arm Length Price and no adjustment\nwas proposed on these transactions. With respect to specified\ndomestic transactions, the TPO observed that the deduction\nclaimed under section 80IA of the Act on the profits

DLF CYBER CITY DEVELOPERS LTD.,GURGAON vs. ADDL. CIT, GURGAON

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

Bench: Shri C. N. Prasad & Shri M. Balaganeshacit, Vs. Dlf Cyber City Developers Ltd, 3Rd Floor, B-Wing, Shopping Mall Circle-1(1), Gurugram Complex, Arjun Marg, Dkf City, Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H Dlf Cyber City Developers Ltd, Vs. Addl. Cit, 3Rd Floor, B-Wing, Shopping Mall Range-I, Complex, Arjun Marg, Dkf City, Gurgaon Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H

801A(4) of the Act, at Page 62-63 of the assessment order. 7. That on the facts and in the circumstances of the case, the Ld. CIT (A) erred in law in upholding the order of Assessing Officer in bringing to tax a sum of 41,09,179 on account of 'Profit on sale of Fixed Assets' under

DLF CYBER CITY DEVELOPERS LTD.,GURUGRAM vs. DCIT, CIRCLE-1(1), GURUGRAM

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

Bench: Shri C. N. Prasad & Shri M. Balaganeshacit, Vs. Dlf Cyber City Developers Ltd, 3Rd Floor, B-Wing, Shopping Mall Circle-1(1), Gurugram Complex, Arjun Marg, Dkf City, Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H Dlf Cyber City Developers Ltd, Vs. Addl. Cit, 3Rd Floor, B-Wing, Shopping Mall Range-I, Complex, Arjun Marg, Dkf City, Gurgaon Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H

801A(4) of the Act, at Page 62-63 of the assessment order. 7. That on the facts and in the circumstances of the case, the Ld. CIT (A) erred in law in upholding the order of Assessing Officer in bringing to tax a sum of 41,09,179 on account of 'Profit on sale of Fixed Assets' under

DLF CYBER CITY DEVELOPERS LTD.,GURUGRAM vs. DCIT, CIRCLE-1, GURUGRAM

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

Bench: Shri C. N. Prasad & Shri M. Balaganeshacit, Vs. Dlf Cyber City Developers Ltd, 3Rd Floor, B-Wing, Shopping Mall Circle-1(1), Gurugram Complex, Arjun Marg, Dkf City, Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H Dlf Cyber City Developers Ltd, Vs. Addl. Cit, 3Rd Floor, B-Wing, Shopping Mall Range-I, Complex, Arjun Marg, Dkf City, Gurgaon Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H

801A(4) of the Act, at Page 62-63 of the assessment order. 7. That on the facts and in the circumstances of the case, the Ld. CIT (A) erred in law in upholding the order of Assessing Officer in bringing to tax a sum of 41,09,179 on account of 'Profit on sale of Fixed Assets' under

DLF CYBER CITY DEVELOPERS LTD.,GURUGRAM vs. DCIT, CIRCLE-1(1), GURUGRAM

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

Bench: Shri C. N. Prasad & Shri M. Balaganeshacit, Vs. Dlf Cyber City Developers Ltd, 3Rd Floor, B-Wing, Shopping Mall Circle-1(1), Gurugram Complex, Arjun Marg, Dkf City, Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H Dlf Cyber City Developers Ltd, Vs. Addl. Cit, 3Rd Floor, B-Wing, Shopping Mall Range-I, Complex, Arjun Marg, Dkf City, Gurgaon Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H

801A(4) of the Act, at Page 62-63 of the assessment order. 7. That on the facts and in the circumstances of the case, the Ld. CIT (A) erred in law in upholding the order of Assessing Officer in bringing to tax a sum of 41,09,179 on account of 'Profit on sale of Fixed Assets' under

ACIT, CIRCLE-1(1), GURUGRAM vs. DLF CYBER CITY DEVELOPERS LTD., GURUGRAM

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

Bench: Shri C. N. Prasad & Shri M. Balaganeshacit, Vs. Dlf Cyber City Developers Ltd, 3Rd Floor, B-Wing, Shopping Mall Circle-1(1), Gurugram Complex, Arjun Marg, Dkf City, Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H Dlf Cyber City Developers Ltd, Vs. Addl. Cit, 3Rd Floor, B-Wing, Shopping Mall Range-I, Complex, Arjun Marg, Dkf City, Gurgaon Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H

801A(4) of the Act, at Page 62-63 of the assessment order. 7. That on the facts and in the circumstances of the case, the Ld. CIT (A) erred in law in upholding the order of Assessing Officer in bringing to tax a sum of 41,09,179 on account of 'Profit on sale of Fixed Assets' under

DLF CYBER CITY DEVELOPERS LTD.,GURUGRAM vs. DCIT, CIRCLE-1(1), GURUGRAM

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

Bench: Shri C. N. Prasad & Shri M. Balaganeshacit, Vs. Dlf Cyber City Developers Ltd, 3Rd Floor, B-Wing, Shopping Mall Circle-1(1), Gurugram Complex, Arjun Marg, Dkf City, Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H Dlf Cyber City Developers Ltd, Vs. Addl. Cit, 3Rd Floor, B-Wing, Shopping Mall Range-I, Complex, Arjun Marg, Dkf City, Gurgaon Phase-I, Gurgaon, Haryana (Appellant) (Respondent) Pan: Aaccd3572H

801A(4) of the Act, at Page 62-63 of the assessment order. 7. That on the facts and in the circumstances of the case, the Ld. CIT (A) erred in law in upholding the order of Assessing Officer in bringing to tax a sum of 41,09,179 on account of 'Profit on sale of Fixed Assets' under

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

In the result, appeal of the assessee is partly allowed

4) of the Act. On transfer of electricity. Ground Nos.3 to 3.1\nare in relation to the adjustment made at INR 32,68,31,286/- by\n\nTPO on the price of power charged by eligible unit to non-eligible\nunit. Ground Nos.4 to 4.1 are in relation to the adjustment of INR\n51,63,85,174/- made by TPO/AO

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

In the result, appeal of the assessee is partly allowed

4) of the Act. On transfer of electricity. Ground Nos.3 to 3.1\nare in relation to the adjustment made at INR 32,68,31,286/- by\n10. At the outset, before us, Ld.AR of the assessee submits that\nthe issue with respect to the transfer of electricity from eligible unit\nto non-eligible unit is covered by the judgement

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. 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

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

BHARTI TELEMEDIA LIMITED,NEW DELHI vs. DCIT, CIRCLE-4(2), NEW DELHI

In the result, the appeals of the Assessee are allowed and appeals of the Revenue are dismissed

Bench: Shri C.N. Prasad & Shri M. Balaganesh

4) This section applies to- …….. (ii) any undertaking which has started or starts providing telecommunication services, whether basic or cellular, including radio paging, domestic satellite service, network of trunking, broadband network and internet services on or after the 1st day of April, 1995, but on or before the 31st day of March, 2005. Explanation. For the purposes of this clause