DCM SHRIRAM LTD,NEW DELHI vs. ACIT, CIRCLE-7(1), 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.\n44. Further Honourable Gujarat High court in Principal Commissioner of\nIncome

DCIT, NEW DELHI vs. DCM SHRIRAM LTD, 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

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

In the result, appeal of the assessee is partly allowed

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

DEV PRIYA PRODUCTS PRIVATE LTD.,DELHI vs. DCIT, CENTRAL CIRCLE, MEERUT

In the result, appeal of the assessee is partly allowed

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2020-21] Dev Priya Products Pvt.Ltd., Vs Dcit/Acit, 4, Shankar Vihar, 1St Floor, Central Circle, Vikas Marg, Delhi-110092. Meerut Pan-Aaacd4276C Appellant Respondent Appellant By Shri Ved Jain, Adv. & Shri Ayush Garg, Ca Respondent By Shri S.K.Jhadav, Cit Dr Date Of Hearing 02.04.2025 Date Of Pronouncement 27.06.2025 Order

price of steam at cost. This order has been accepted by the revenue and no further appeal has been filed. Therefore this issue becomes final with respect to the determination of ALP of transfer of steam at cost by the eligible unit to non eligible unit. 44. Further Honourable Gujarat High court in Principal Commissioner of Income

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

In the result, appeal of the assessee is partly allowed

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

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

price at Rs.22.58 lakhs. 81. So far as Dabur Nepal Pvt. Ltd., Nepal is concerned, the CIT(A) observed that Rate of 3% is mentioned in the amended agreement and the assessee could not meet its obligation to bear entire marketing expenses and therefore, Dabur Nepal Pvt. Ltd, Nepal did not pay any royalty. Accordingly, the ld. CIT(A) applied

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

price at Rs.22.58 lakhs. 81. So far as Dabur Nepal Pvt. Ltd., Nepal is concerned, the CIT(A) observed that Rate of 3% is mentioned in the amended agreement and the assessee could not meet its obligation to bear entire marketing expenses and therefore, Dabur Nepal Pvt. Ltd, Nepal did not pay any royalty. Accordingly, the ld. CIT(A) applied

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

price at Rs.22.58 lakhs. 81. So far as Dabur Nepal Pvt. Ltd., Nepal is concerned, the CIT(A) observed that Rate of 3% is mentioned in the amended agreement and the assessee could not meet its obligation to bear entire marketing expenses and therefore, Dabur Nepal Pvt. Ltd, Nepal did not pay any royalty. Accordingly, the ld. CIT(A) applied

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

price at Rs.22.58 lakhs. 81. So far as Dabur Nepal Pvt. Ltd., Nepal is concerned, the CIT(A) observed that Rate of 3% is mentioned in the amended agreement and the assessee could not meet its obligation to bear entire marketing expenses and therefore, Dabur Nepal Pvt. Ltd, Nepal did not pay any royalty. Accordingly, the ld. CIT(A) applied

GREAT EASTERN EXPORTS vs. ASSISTANT COMMISSIONER OF INCOME TAX

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

transfer, in either case, had been made at the market value of such goods or services as on that date. Explanation.--For the purposes of this sub-section, the expression “market value”,-- (i) in relation to any goods or services sold or supplied, means the price that such goods or services would fetch if these were sold by the undertaking

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

prices with retrospective effect have always been accepted as revenue deduction, including payments made during the relevant year. Therefore according to him , during the relevant previous year, the appellant made aggregate provision of Rs. 6159.90 lacs, comprising of Provision for purchase orders issued for price amendment as at 31.3.2012 of Rs. 1034.90 lacs and Provision on estimated basis for price

GAIL (INDIA) LTD.,NEW DELHI vs. DCIT-LTU DELHI, NEW DELHI

Appeal is dismissed

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

transferred to GAIL. The same gas was sold by ONGC through GAIL to the same customers. The existing agreement between ONGC and customers were assigned in the favour of GAIL. Therefore, GAIL was not an industrial undertaking in respect of or production in terms of Section 80IA/80I/80HH. The Ld. DR pointed out that the price

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

Appeal is dismissed

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

transferred to GAIL. The same gas was sold by ONGC through GAIL to the same customers. The existing agreement between ONGC and customers were assigned in the favour of GAIL. Therefore, GAIL was not an industrial undertaking in respect of or production in terms of Section 80IA/80I/80HH. The Ld. DR pointed out that the price

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

The appeal of the assessee is partly allowed for statistical purpose

Bench: Shri Anil Chaturvedi & Ms Suchitra Kamble(Through Video Conferencing) Vs Havells India Ltd. Acit 1, Raj Narian Marg, Ltu Civil Lines New Delhi New Delhi Aaach0351E (Respondent) (Appellant)

80I of the Act. Thus, the Ld. AR submitted that the action of the Assessing Officer/CIT(A) in reducing the amount of deduction claimed by assessee under Section 80-IC of the Act in respect of Baddi Unit-II and Haridwar Unit, by notionally bringing forward losses already set off against income of preceding assessment years, is legally unsustainable

C.I.T vs. JACKSON ENGINEERS LTD

Appeal stands disposed of in the

Bench: HON'BLE MR. JUSTICE A.K.SIKRI,HON'BLE MR. JUSTICE SIDDHARTH MRIDUL

80I as the Legislature intended to give benefit of deduction not only to profits derived from the undertaking but also to give benefit of deduction in respect of incomes having direct nexus with the profits of the undertaking, hence, all incomes that arose during the course of running of the eligible business would be eligible for deduction under Section 80IB

Commissioner of Income Tax vs. Jackson Engineers Ltd.

Appeal stands disposed of in the

80I as the Legislature intended to give benefit of deduction not only to profits derived from the undertaking but also to give benefit of deduction in respect of incomes having direct nexus with the profits of the undertaking, hence, all incomes that arose during the course of running of the eligible business would be eligible for deduction under Section 80IB

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)

Transfer Pricing Study to determine "ordinary profit" for the purpose of section 10A(7) read with section 80IA(10) of the Act. 2.4. Based on the facts and the circumstances of the case and in law, the Hon'ble CIT (A) has erred in not appreciating the various judicial precedents relied upon by the appellant in this regard. 2.5. Without

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)

Transfer Pricing Study to determine "ordinary profit" for the purpose of section 10A(7) read with section 80IA(10) of the Act. 2.4. Based on the facts and the circumstances of the case and in law, the Hon'ble CIT (A) has erred in not appreciating the various judicial precedents relied upon by the appellant in this regard. 2.5. Without