M/S DABUR INDIA LTD.,,DELHI vs. ACIT, NEW DELHI

In the result appeal of the assessee is partly allowed for statistical purposes and that of the department is dismissed

Bench: Sh. N. K. Saini, Am & Sh. Sudhanshu Srivastava, Jm Ita No. 3257/Del/2013 : Asstt. Year : 2006-07 Dabur India Ltd., Vs Asstt. Commissioner Of Income 8/3, Asaf Ali Road, Tax, Central Circle-22, New Delhi New Delhi (Appellant) (Respondent) Pan No. Aaacd0474C

section 801B & 801C of the Act, 1961? 7. The appellant craves leave, to add, alter or amend any ground of appeal raised above at the time of the hearing.” 5. Ground Nos. 1 to 7 of the assessee’s appeal which are co-related and Ground Nos. 1 & 2 of the departmental appeal relate to the chargeability of the royalty

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

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 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. M/S. DABUR INDIA LTD., NEW DELHI

In the result, the appeals filed by the Revenue are partly allowed and the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri R.K. Panda & Ms Suchitra Kamble

Transfer Pricing Officer for determination of the ALP of the international transactions entered into by the assessee with its AEs as per report in Form No.3CEB u/s 92E of the Act. The TPO proposed an upward adjustment of Rs.3,95,44,120/- on account of the following:- a) Adjustment on account of guarantee - Rs.32,09,600/- b) Adjustment on account

DCIT, NEW DELHI vs. M/S. DABUR INDIA LTD., NEW DELHI

In the result, the appeals filed by the Revenue are partly allowed and the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri R.K. Panda & Ms Suchitra Kamble

Transfer Pricing Officer for determination of the ALP of the international transactions entered into by the assessee with its AEs as per report in Form No.3CEB u/s 92E of the Act. The TPO proposed an upward adjustment of Rs.3,95,44,120/- on account of the following:- a) Adjustment on account of guarantee - Rs.32,09,600/- b) Adjustment on account

M/S. DABUR INDIA LTD.,NEW DELHI vs. ADDL.CIT, NEW DELHI

In the result, the appeals filed by the Revenue are partly allowed and the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri R.K. Panda & Ms Suchitra Kamble

Transfer Pricing Officer for determination of the ALP of the international transactions entered into by the assessee with its AEs as per report in Form No.3CEB u/s 92E of the Act. The TPO proposed an upward adjustment of Rs.3,95,44,120/- on account of the following:- a) Adjustment on account of guarantee - Rs.32,09,600/- b) Adjustment on account

M/S. DABUR INDIA LTD.,NEW DELHI vs. ADDL.CIT, NEW DELHI

In the result, the appeals filed by the Revenue are partly allowed and the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri R.K. Panda & Ms Suchitra Kamble

Transfer Pricing Officer for determination of the ALP of the international transactions entered into by the assessee with its AEs as per report in Form No.3CEB u/s 92E of the Act. The TPO proposed an upward adjustment of Rs.3,95,44,120/- on account of the following:- a) Adjustment on account of guarantee - Rs.32,09,600/- b) Adjustment on account

DABUR INDIA LTD.,NEW DELHI vs. DCIT, CIRCLE-7(1), NEW DELHI

In the result, all these appeals are allowed for statistical purposes

801B and 80IC under the head profit and gains. 6. Ld Commissioner of Income-tax (Appeals) erred in law on the facts of the case in deleting the addition of Rs.2,18,081/- made by the AO on account of PF, ESI & EPS contribution after the due date. 7. Ld Commissioner of Income-tax (Appeals) erred

DCIT, CIRCLE-7(1), NEW DELHI vs. DABUR INDIA LTD., NEW DELHI

In the result, all these appeals are allowed for statistical purposes

801B and 80IC under the head profit and gains. 6. Ld Commissioner of Income-tax (Appeals) erred in law on the facts of the case in deleting the addition of Rs.2,18,081/- made by the AO on account of PF, ESI & EPS contribution after the due date. 7. Ld Commissioner of Income-tax (Appeals) erred

DABUR INDIA LTD.,NEW DELHI vs. DCIT, CIRCLE- 7(1), NEW DELHI

In the result, all these appeals are allowed for statistical purposes

801B and 80IC under the head profit and gains. 6. Ld Commissioner of Income-tax (Appeals) erred in law on the facts of the case in deleting the addition of Rs.2,18,081/- made by the AO on account of PF, ESI & EPS contribution after the due date. 7. Ld Commissioner of Income-tax (Appeals) erred

DCIT, CIRCLE- 7(1), NEW DELHI vs. DABUR INDIA LTD., NEW DELHI

In the result, all these appeals are allowed for statistical purposes

801B and 80IC under the head profit and gains. 6. Ld Commissioner of Income-tax (Appeals) erred in law on the facts of the case in deleting the addition of Rs.2,18,081/- made by the AO on account of PF, ESI & EPS contribution after the due date. 7. Ld Commissioner of Income-tax (Appeals) erred

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

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 to above

DABUR INDIA LTD.,NEW DELHI vs. DCIT, CIRCLE- 7(1), NEW DELHI

In the result, the appeal of the assessee is allowed in part for statistical purpose

Bench: Sh. Saktijit Dey & Sh. N. K. Billaiya

transfer pricing, we do not find any infirmity in the order of ld. CIT(A) that there is no reason to separately benchmark receivables”. 39. The following chart also shows that the margin of the assessee both in the FMCG and non- FMCG segment is much higher than the comparables as demonstrated here under :- 40. Considering the facts

ACIT, CIRCLE- 7(1), NEW DELHI vs. DABUR INDIA LTD., NEW DELHI

In the result, the appeal of the assessee is allowed in part for statistical purpose

Bench: Sh. Saktijit Dey & Sh. N. K. Billaiya

transfer pricing, we do not find any infirmity in the order of ld. CIT(A) that there is no reason to separately benchmark receivables”. 39. The following chart also shows that the margin of the assessee both in the FMCG and non- FMCG segment is much higher than the comparables as demonstrated here under :- 40. Considering the facts

DABUR INDIA LTD.,NEW DELHI vs. DCIT, CIRCLE- 7(1), NEW DELHI

In the result, the appeal of the assessee is allowed in part for statistical purpose

Bench: Sh. Saktijit Dey & Sh. N. K. Billaiya

transfer pricing, we do not find any infirmity in the order of ld. CIT(A) that there is no reason to separately benchmark receivables”. 39. The following chart also shows that the margin of the assessee both in the FMCG and non- FMCG segment is much higher than the comparables as demonstrated here under :- 40. Considering the facts

ACIT, CIRCLE- 7(1), NEW DELHI vs. DABUR INDIA LTD., NEW DELHI

In the result, the appeal of the assessee is allowed in part for statistical purpose

Bench: Sh. Saktijit Dey & Sh. N. K. Billaiya

transfer pricing, we do not find any infirmity in the order of ld. CIT(A) that there is no reason to separately benchmark receivables”. 39. The following chart also shows that the margin of the assessee both in the FMCG and non- FMCG segment is much higher than the comparables as demonstrated here under :- 40. Considering the facts

DABUR INDIA LTD.,NEW DELHI vs. DCIT, CIRCLE- 7(1), NEW DELHI

In the result, the appeal of the assessee is allowed in part for statistical purpose

Bench: Sh. Saktijit Dey & Sh. N. K. Billaiya

transfer pricing, we do not find any infirmity in the order of ld. CIT(A) that there is no reason to separately benchmark receivables”. 39. The following chart also shows that the margin of the assessee both in the FMCG and non- FMCG segment is much higher than the comparables as demonstrated here under :- 40. Considering the facts