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:

Transfer Pricing Order u/s. No. Entity Year 92CA(3) Paper Book Page 1. LHCC 2014-15 849-850 2. 2015-16 851-852 3. 2017-18 853-854 4. 2018-19 855-857 5. 2014-15 858-859 6. KC 2017-18 860-861 DCIT vs. Lotus Hearbals Pvt. Ltd. f) Further, allocation of AMP expenses, on a highly

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:

Transfer Pricing Order u/s. No. Entity Year 92CA(3) Paper Book Page 1. LHCC 2014-15 849-850 2. 2015-16 851-852 3. 2017-18 853-854 4. 2018-19 855-857 5. 2014-15 858-859 6. KC 2017-18 860-861 DCIT vs. Lotus Hearbals Pvt. Ltd. f) Further, allocation of AMP expenses, on a highly

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:

Transfer Pricing Order u/s. No. Entity Year 92CA(3) Paper Book Page 1. LHCC 2014-15 849-850 2. 2015-16 851-852 3. 2017-18 853-854 4. 2018-19 855-857 5. 2014-15 858-859 6. KC 2017-18 860-861 DCIT vs. Lotus Hearbals Pvt. Ltd. f) Further, allocation of AMP expenses, on a highly

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:

Transfer Pricing Order u/s. No. Entity Year 92CA(3) Paper Book Page 1. LHCC 2014-15 849-850 2. 2015-16 851-852 3. 2017-18 853-854 4. 2018-19 855-857 5. 2014-15 858-859 6. KC 2017-18 860-861 DCIT vs. Lotus Hearbals Pvt. Ltd. f) Further, allocation of AMP expenses, on a highly

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:

Transfer Pricing Order u/s. No. Entity Year 92CA(3) Paper Book Page 1. LHCC 2014-15 849-850 2. 2015-16 851-852 3. 2017-18 853-854 4. 2018-19 855-857 5. 2014-15 858-859 6. KC 2017-18 860-861 DCIT vs. Lotus Hearbals Pvt. Ltd. f) Further, allocation of AMP expenses, on a highly

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:

Transfer Pricing Order u/s. No. Entity Year 92CA(3) Paper Book Page 1. LHCC 2014-15 849-850 2. 2015-16 851-852 3. 2017-18 853-854 4. 2018-19 855-857 5. 2014-15 858-859 6. KC 2017-18 860-861 DCIT vs. Lotus Hearbals Pvt. Ltd. f) Further, allocation of AMP expenses, on a highly

ACIT, CIRCLE- 1, LTU, NEW DELHI vs. C&S ELECTRIC LTD., NEW DELHI

In the result, the revenue’s appeal stands dismissed as above

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishraita No. 2622/Del/2018, A.Y. 2013-14 Ita No. 2623/Del/2018, A.Y. 2014-15 Ita No. 7981/Del/2018, A.Y. 2015-16 C & S Electric Limited Deputy Commissioner Of 222, Okhla Industrial Estate Income Tax, Phase-Iii, New Delhi Vs. Circle-1, Ltu, New Delhi Pan: Aaacc0909K (Appellant) (Respondent) Ita No. 2532/Del/2018, A.Y.2013-14 Ita No. 2533/Del/2018, A.Y.2014-15 Ita No. 8274/Del/2018, A.Y.2015-16 Deputy Commissioner Of C & S Electric Limited Income Tax, (Formerly Controls & Circle-1, Ltu, Vs. Switchgear Co. Ltd.) New Delhi 222, Okhla Industrial Estate, Phase-Iii, New Delhi Pan: Aaacc0909K (Appellant) (Respondent) Appellant By Sh. Anil Bhalla, Ca Respondent By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 05/06/2025 Date Of Pronouncement 30/06/2025 Order Per Bench Cross Appeal By The Assessee & Revenue Containing Common Facts Were Heard Together Being Inter-Connected With Each Other & Are Being Disposed Off By This Common Order. Ita No.2532, 2533 & 8274/Del/2018 C & S Electric Ltd. 2. These Appeals Filed By The Assessee & Revenue Are Directed Against Orders Dated 10.01.18 & 25.09.2018 Respectively Of The Commissioner Of Income Tax (Appeals)-22, New Delhi [‘Cit(A)’].

section 80IC and 10AA of the Act: “4.4 In year under consideration the details filed by the authorized representative show that some goods are transferred at lower rates and some are at higher rate as compared to rates charged to outside parties. The authorized representative has submitted that the net difference (Overcharge) of (74,95,918/-) may be allowed

DCIT, CIRCLE- 1, LTU, NEW DELHI vs. C & S ELECTRIC LTD., NEW DELHI

In the result, the revenue’s appeal stands dismissed as above

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishraita No. 2622/Del/2018, A.Y. 2013-14 Ita No. 2623/Del/2018, A.Y. 2014-15 Ita No. 7981/Del/2018, A.Y. 2015-16 C & S Electric Limited Deputy Commissioner Of 222, Okhla Industrial Estate Income Tax, Phase-Iii, New Delhi Vs. Circle-1, Ltu, New Delhi Pan: Aaacc0909K (Appellant) (Respondent) Ita No. 2532/Del/2018, A.Y.2013-14 Ita No. 2533/Del/2018, A.Y.2014-15 Ita No. 8274/Del/2018, A.Y.2015-16 Deputy Commissioner Of C & S Electric Limited Income Tax, (Formerly Controls & Circle-1, Ltu, Vs. Switchgear Co. Ltd.) New Delhi 222, Okhla Industrial Estate, Phase-Iii, New Delhi Pan: Aaacc0909K (Appellant) (Respondent) Appellant By Sh. Anil Bhalla, Ca Respondent By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 05/06/2025 Date Of Pronouncement 30/06/2025 Order Per Bench Cross Appeal By The Assessee & Revenue Containing Common Facts Were Heard Together Being Inter-Connected With Each Other & Are Being Disposed Off By This Common Order. Ita No.2532, 2533 & 8274/Del/2018 C & S Electric Ltd. 2. These Appeals Filed By The Assessee & Revenue Are Directed Against Orders Dated 10.01.18 & 25.09.2018 Respectively Of The Commissioner Of Income Tax (Appeals)-22, New Delhi [‘Cit(A)’].

section 80IC and 10AA of the Act: “4.4 In year under consideration the details filed by the authorized representative show that some goods are transferred at lower rates and some are at higher rate as compared to rates charged to outside parties. The authorized representative has submitted that the net difference (Overcharge) of (74,95,918/-) may be allowed

C & S ELECTRIC LTD.,NEW DELHI vs. DCIT, CIRCLE- 1, LTU, NEW DELHI

In the result, the revenue’s appeal stands dismissed as above

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishraita No. 2622/Del/2018, A.Y. 2013-14 Ita No. 2623/Del/2018, A.Y. 2014-15 Ita No. 7981/Del/2018, A.Y. 2015-16 C & S Electric Limited Deputy Commissioner Of 222, Okhla Industrial Estate Income Tax, Phase-Iii, New Delhi Vs. Circle-1, Ltu, New Delhi Pan: Aaacc0909K (Appellant) (Respondent) Ita No. 2532/Del/2018, A.Y.2013-14 Ita No. 2533/Del/2018, A.Y.2014-15 Ita No. 8274/Del/2018, A.Y.2015-16 Deputy Commissioner Of C & S Electric Limited Income Tax, (Formerly Controls & Circle-1, Ltu, Vs. Switchgear Co. Ltd.) New Delhi 222, Okhla Industrial Estate, Phase-Iii, New Delhi Pan: Aaacc0909K (Appellant) (Respondent) Appellant By Sh. Anil Bhalla, Ca Respondent By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 05/06/2025 Date Of Pronouncement 30/06/2025 Order Per Bench Cross Appeal By The Assessee & Revenue Containing Common Facts Were Heard Together Being Inter-Connected With Each Other & Are Being Disposed Off By This Common Order. Ita No.2532, 2533 & 8274/Del/2018 C & S Electric Ltd. 2. These Appeals Filed By The Assessee & Revenue Are Directed Against Orders Dated 10.01.18 & 25.09.2018 Respectively Of The Commissioner Of Income Tax (Appeals)-22, New Delhi [‘Cit(A)’].

section 80IC and 10AA of the Act: “4.4 In year under consideration the details filed by the authorized representative show that some goods are transferred at lower rates and some are at higher rate as compared to rates charged to outside parties. The authorized representative has submitted that the net difference (Overcharge) of (74,95,918/-) may be allowed

ITO WARD - 10(4), NEW DELHI vs. GHP BUILDCON PVT LTD, NEW DELHI

In the result, the revenue’s appeal stands dismissed as above

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishraita No. 2622/Del/2018, A.Y. 2013-14 Ita No. 2623/Del/2018, A.Y. 2014-15 Ita No. 7981/Del/2018, A.Y. 2015-16 C & S Electric Limited Deputy Commissioner Of 222, Okhla Industrial Estate Income Tax, Phase-Iii, New Delhi Vs. Circle-1, Ltu, New Delhi Pan: Aaacc0909K (Appellant) (Respondent) Ita No. 2532/Del/2018, A.Y.2013-14 Ita No. 2533/Del/2018, A.Y.2014-15 Ita No. 8274/Del/2018, A.Y.2015-16 Deputy Commissioner Of C & S Electric Limited Income Tax, (Formerly Controls & Circle-1, Ltu, Vs. Switchgear Co. Ltd.) New Delhi 222, Okhla Industrial Estate, Phase-Iii, New Delhi Pan: Aaacc0909K (Appellant) (Respondent) Appellant By Sh. Anil Bhalla, Ca Respondent By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 05/06/2025 Date Of Pronouncement 30/06/2025 Order Per Bench Cross Appeal By The Assessee & Revenue Containing Common Facts Were Heard Together Being Inter-Connected With Each Other & Are Being Disposed Off By This Common Order. Ita No.2532, 2533 & 8274/Del/2018 C & S Electric Ltd. 2. These Appeals Filed By The Assessee & Revenue Are Directed Against Orders Dated 10.01.18 & 25.09.2018 Respectively Of The Commissioner Of Income Tax (Appeals)-22, New Delhi [‘Cit(A)’].

section 80IC and 10AA of the Act: “4.4 In year under consideration the details filed by the authorized representative show that some goods are transferred at lower rates and some are at higher rate as compared to rates charged to outside parties. The authorized representative has submitted that the net difference (Overcharge) of (74,95,918/-) may be allowed

C & S ELECTRIC LTD.,NEW DELHI vs. DCIT, CIRCLE- 1, LTU, NEW DELHI

In the result, the revenue's appeal stands dismissed as above

section 80IC and 10AA of the Act:\n“4.4 In year under consideration the details filed by the authorized\nrepresentative show that some goods are transferred at lower rates and\nsome are at higher rate as compared to rates charged to outside parties.\nThe authorized representative has submitted that the net difference\n(Overcharge

M/S. HAVELLS INDIA LTD.,DELHI vs. DCIT (LTU), NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

Transfer Pricing Officer (TPO) under section 92CA(3) of the Act. 2 Havells India Ltd. 2.02. That on the facts and in the circumstances of the case and the legal position, the learned CIT (A) has erred in confirming an addition of Rs.11,62,00,000/- allegedly on the ground that no commission has been charged by the appellant

DCIT, NEW DELHI vs. SHRI SUBASH CHANDER SEHGAL, NEW DELHI

In the result, the appeal of the Revenue is dismissed for AY 2009-10

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2004-05 Asstt. Year: 2006-07 Asstt. Year: 2009-10

prices undertaken between sister concerns; - No instance has been brought on record by the A.O. xvi) Sales and purchases are not fully declared. - The A.O. has not given any basis or any supporting evidence to justify the same. 4.42 Further 1 have seen and verified that the appellant has maintained all relevant records, namely the raw material stock register

ACIT, NEW DELHI vs. SH. SUBHASH CHANDER SEHGAL, NEW DELHI

In the result, the appeal of the Revenue is dismissed for AY 2009-10

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2004-05 Asstt. Year: 2006-07 Asstt. Year: 2009-10

prices undertaken between sister concerns; - No instance has been brought on record by the A.O. xvi) Sales and purchases are not fully declared. - The A.O. has not given any basis or any supporting evidence to justify the same. 4.42 Further 1 have seen and verified that the appellant has maintained all relevant records, namely the raw material stock register

DCIT, NEW DELHI vs. SH. SUBHASH CHANDRA SEHGAL, NEW DELHI

In the result, the appeal of the Revenue is dismissed for AY 2009-10

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2004-05 Asstt. Year: 2006-07 Asstt. Year: 2009-10

prices undertaken between sister concerns; - No instance has been brought on record by the A.O. xvi) Sales and purchases are not fully declared. - The A.O. has not given any basis or any supporting evidence to justify the same. 4.42 Further 1 have seen and verified that the appellant has maintained all relevant records, namely the raw material stock register

JCIT SPL. RANGE-12, NEW DELHI vs. ARIHANTA INDUSTRIES, DELHI

In the result, both the appeals of the Revenue are allowed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

801C for profits derived from manufacturing activity were found to be entirely bogus. 6. The Ld. CIT(A) erred in law by not considering the facts that the during the assessment proceedings, the AO issued summons u/s 131 of the Act to sales parties in order to get confirmations and to substantiate the genuineness of the transactions but all remain

SUBHASH CHANDER SEHGAL,NEW DELHI vs. DCIT, CIRCLE- 19 (1) & (2), NEW DELHI

In the result, appeal of the assessee is partly allowed

Bench: Shri G.S. Pannu, Hon’Ble & Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.3814/Del/2015 िनधा"रणवष"/Assessment Year:2010-11 बनाम Dcit Subhash Chander Sehgal, Circle 19(1) Vs. Block A-3, Lsc, Janakpuri, New Delhi. Delhi. Pan No.Aatps8259C अपीलाथ" Appellant ""यथ"/Respondent

801C, there is no restriction regarding number of workers to be engaged in the industrial I.T.A.Nos.3814/Del/2015, 5420 & 7426/Del/2017 undertaking. Therefore, disallowance of deduction u/s 80IC by the AO on the ground that required number of workers were not engaged in Guwahati unit, is erroneous and disallowance on this ground cannot be sustained. Although the number of workers being engaged

SUBHASH CHANDER SEHGAL,NEW DELHI vs. DCIT, CIRCLE- 19(1) & 19(2), NEW DELHI

In the result, appeal of the assessee is partly allowed

Bench: Shri G.S. Pannu, Hon’Ble & Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.3814/Del/2015 िनधा"रणवष"/Assessment Year:2010-11 बनाम Dcit Subhash Chander Sehgal, Circle 19(1) Vs. Block A-3, Lsc, Janakpuri, New Delhi. Delhi. Pan No.Aatps8259C अपीलाथ" Appellant ""यथ"/Respondent

801C, there is no restriction regarding number of workers to be engaged in the industrial I.T.A.Nos.3814/Del/2015, 5420 & 7426/Del/2017 undertaking. Therefore, disallowance of deduction u/s 80IC by the AO on the ground that required number of workers were not engaged in Guwahati unit, is erroneous and disallowance on this ground cannot be sustained. Although the number of workers being engaged

DCIT, NEW DELHI vs. SH. SUBHASH CHANDER SEHGAL, DELHI

In the result, appeal of the assessee is partly allowed

Bench: Shri G.S. Pannu, Hon’Ble & Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.3814/Del/2015 िनधा"रणवष"/Assessment Year:2010-11 बनाम Dcit Subhash Chander Sehgal, Circle 19(1) Vs. Block A-3, Lsc, Janakpuri, New Delhi. Delhi. Pan No.Aatps8259C अपीलाथ" Appellant ""यथ"/Respondent

801C, there is no restriction regarding number of workers to be engaged in the industrial I.T.A.Nos.3814/Del/2015, 5420 & 7426/Del/2017 undertaking. Therefore, disallowance of deduction u/s 80IC by the AO on the ground that required number of workers were not engaged in Guwahati unit, is erroneous and disallowance on this ground cannot be sustained. Although the number of workers being engaged