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. 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

price as defined in clause (ii) of\nSection 92F of the Act where the transfer of such goods is a\nspecified domestic transaction in Section 92BA of the Act. Both\nclause (iii) of the Explanation to Section 80A

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

In the result, appeal of the assessee is partly allowed

price as defined in clause (ii) of\nSection 92F of the Act where the transfer of such goods is a\nspecified domestic transaction in Section 92BA of the Act. Both\nclause (iii) of the Explanation to Section 80A

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

priced when transferred to other unit. On perusal of the provisions of sub- section (6) of Section 80A and Section

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

In the result, the appeal filed by the assessee is allowed in above terms

Bench: Shri Challa Nagemdra Prasad & Shri S. Rifaur Rahman

pricing adjustment made in respect of transfer of steam is hereby deleted and hence grounds of appeal no.5 to 7 raised by the assessee in this respect are allowed. Ground no 8 and 9: Enhanced Claim of deduction u/s 80-IA on transfer of steam 14 17. The next issue which relates to above issue is, with reference

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

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 have not noticed

PR. COMMISSIONER OF INCOME TAX-7 vs. SMR AUTOMOTIVE SYSTEMS INDIA LTD.

80A; (iii) any transfer of goods or services referred to in sub-section (8) of section 80-IA; (iv) any business transacted between the assessee and other person as referred to in sub-section (10) of section 80-IA.” 5. The Tribunal appears to have taken the position that since sub-clause (1) of Section 92BA had been omitted, transfer

DCIT, CIRCLE-14(2), NEW DELHI vs. KINDLE ENGINEERING AND CONSTRUCTION PVT. LTD., NEW DELHI

In the result, the appeal of the Revenue is dismissed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

80A: (iii) any transfer of goods or services referred to in sub- section (8) of section 80-1 A: (iv) any business transacted between the assessee and other person as referred to in sub-section (10) of section 80-1 A: (v) any transaction, referred to in any other section under Chapter VI-A or section I0AA, to which provisions

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-19, NEW DELHI vs. KOYA AND COMPANY CONSTRUCTION LIMITED, HYDERABAD

In the result, the appeal filed by the Revenue is dismissed

Bench: Shris.Rifaur Rahman & Shri Sudhir Pareekdcit, Vs. M/S. Koya & Company Construction Ltd. Central Circle 19, 12-2-831/38/1, 72 Migh, New Delhi. Mehdipatnam, Hyderabad – 500 028 (Telangana). (Pan :Aacck3240R) (Appellant) (Respondent) Assessee By : Shri K.C. Devdas, Ar Revenue By : Shri Shankar Gupta, Sr. Dr Date Of Hearing : 13.10.2025 Date Of Order : 26.11.2025 Order Per S. Rifaur Rahman:

section 92CA(l) of the Act for determination of Arm's length price in respect of the specified domestic transactions reported by the assessee for the assessment year under consideration. 7. The Additional DIT (TP), Hyderabad (TPO) initiated the transfer pricing proceedings and issued notice on November 26, 2019 and January 5, 2021. The assessee filed the details as called

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

transferring & handing over specified bare shell buildings located within the project. This MOU of Co-Developer Agreement was approved by the SEZ authorities vide their approval letter bearing Ref. No. F.2/126/2005-EPZ dated 01.05.2007. The clauses of the Addendum to the MOU for appointment of Co- Developer Agreement, inter alia, included that the assessee, being a Developer shall hand over

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

transferring & handing over specified bare shell buildings located within the project. This MOU of Co-Developer Agreement was approved by the SEZ authorities vide their approval letter bearing Ref. No. F.2/126/2005-EPZ dated 01.05.2007. The clauses of the Addendum to the MOU for appointment of Co- Developer Agreement, inter alia, included that the assessee, being a Developer shall hand over

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

transferring & handing over specified bare shell buildings located within the project. This MOU of Co-Developer Agreement was approved by the SEZ authorities vide their approval letter bearing Ref. No. F.2/126/2005-EPZ dated 01.05.2007. The clauses of the Addendum to the MOU for appointment of Co- Developer Agreement, inter alia, included that the assessee, being a Developer shall hand over

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

transferring & handing over specified bare shell buildings located within the project. This MOU of Co-Developer Agreement was approved by the SEZ authorities vide their approval letter bearing Ref. No. F.2/126/2005-EPZ dated 01.05.2007. The clauses of the Addendum to the MOU for appointment of Co- Developer Agreement, inter alia, included that the assessee, being a Developer shall hand over

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

transferring & handing over specified bare shell buildings located within the project. This MOU of Co-Developer Agreement was approved by the SEZ authorities vide their approval letter bearing Ref. No. F.2/126/2005-EPZ dated 01.05.2007. The clauses of the Addendum to the MOU for appointment of Co- Developer Agreement, inter alia, included that the assessee, being a Developer shall hand over

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

transferring & handing over specified bare shell buildings located within the project. This MOU of Co-Developer Agreement was approved by the SEZ authorities vide their approval letter bearing Ref. No. F.2/126/2005-EPZ dated 01.05.2007. The clauses of the Addendum to the MOU for appointment of Co- Developer Agreement, inter alia, included that the assessee, being a Developer shall hand over