MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

The appeals are allowed in the above terms, but with no orders as to costs

transfer pricing in the form of Sections 92B to 92F. 59. Nevertheless, there is no specific mention of AMP expenses as one of the items of expenditure which can be deemed to be an international transaction. For this purpose, Section 92B(1) read with Section 92

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

The appeals are allowed in the above terms, but with no orders as to costs

transfer pricing in the form of Sections 92B to 92F. 59. Nevertheless, there is no specific mention of AMP expenses as one of the items of expenditure which can be deemed to be an international transaction. For this purpose, Section 92B(1) read with Section 92

DCIT, CIRCLE- 16(2), NEW DELHI vs. MENETA AUTOMOTIVE COMPONENTS PVT. LTD., NEW DELHI

In the result, the appeal of the Revenue is dismissed

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

Transfer Pricing Officer (TPO). Sub-section (3) of Section 92CA provides that the TPO, after taking into account the material available with him shall, by an order in writing, determine the ALP in accordance with sub section (3) of Section 92C of the Act. Sub- section (4) of Section 92CA provides that on receipt of the order

COMMISSIONER OF INCOME TAX vs. MENTOR GRAPHICS (NOIDA) PVT.LTD

The appeal is allowed

92, which is the first section in that chapter, stipulates that any income arising from an international transaction is to be computed having regard to the arm’s length price. “Arm’s length price” is defined in section 92F to mean a price which is applied or proposed to be applied in a transaction between persons other than associated enterprises

EBRO INDIA PVT.LTD. ,DELHI vs. ACIT CIRCLE-7(1), DELHI

In the result, the ground no 4 raised by the assessee is allowed

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Accountant Member)

transfer of jurisdiction to the JAO in the impugned assessment order and/ or any other communication to the appellant. 35. Being so, the impugned order passed by Asst. Commissioner of Income Tax, Circle 7(1) and not by NFAC is, in our respectful submissions, beyond jurisdiction, illegal and bad in law being passed by officer not having jurisdiction

TUPPERWARE INDIA PRIVATE LIMITED,NEW DELHI vs. DCIT,CIRCLE-25(1), NEW DELHI

In the result, the appeal of the assessee for AY 2018-19 is partly allowed for statistical purposes

Bench: Shri Mahavir Singh & Shri M. Balaganesh

92(1) becomes significant. Under Section 92B(1) an 'international transaction' means- (a) a transaction between two or more AEs, either or both of whom are non-resident (b) the transaction is in the nature of purchase, sale or lease of tangible or intangible property or provision of service or lending or borrowing money or any other transaction having

TUPPERWARE INDIA PRIVATE LIMITED,NEW DELHI vs. ACIT, CIRCLE-25(1) , NEW DELHI

In the result, the appeal of the assessee for AY 2018-19 is partly allowed for statistical purposes

Bench: Shri Mahavir Singh & Shri M. Balaganesh

92(1) becomes significant. Under Section 92B(1) an 'international transaction' means- (a) a transaction between two or more AEs, either or both of whom are non-resident (b) the transaction is in the nature of purchase, sale or lease of tangible or intangible property or provision of service or lending or borrowing money or any other transaction having

BAUSCH & LOMB EYECARE (INDIA) PVT. LTD.

The appeals of the Assessee are allowed and the appeals of the Revenue

price"] and Section 92 (1) which states that any income arising from an international transaction shall be computed having regard to the ALP and Section 92C (1) which sets out the different methods of determining the ALP, makes it clear that the transfer

BAUSCH & LOMB EYECARE (INDIA) PVT. LTD.

The appeals of the Assessee are allowed and the appeals of the Revenue

price"] and Section 92 (1) which states that any income arising from an international transaction shall be computed having regard to the ALP and Section 92C (1) which sets out the different methods of determining the ALP, makes it clear that the transfer

BAUSCH & LOMB EYECARE (INDIA) PVT. LTD.

The appeals of the Assessee are allowed and the appeals of the Revenue

price"] and Section 92 (1) which states that any income arising from an international transaction shall be computed having regard to the ALP and Section 92C (1) which sets out the different methods of determining the ALP, makes it clear that the transfer

BAUSCH & LOMB EYECARE (INDIA) PVT. LTD.

The appeals of the Assessee are allowed and the appeals of the Revenue

price"] and Section 92 (1) which states that any income arising from an international transaction shall be computed having regard to the ALP and Section 92C (1) which sets out the different methods of determining the ALP, makes it clear that the transfer

BAUSCH & LOMB EYECARE (INDIA) PVT. LTD.

The appeals of the Assessee are allowed and the appeals of the Revenue

price"] and Section 92 (1) which states that any income arising from an international transaction shall be computed having regard to the ALP and Section 92C (1) which sets out the different methods of determining the ALP, makes it clear that the transfer

BAUSCH & LOMB EYECARE (INDIA) PVT. LTD.

The appeals of the Assessee are allowed and the appeals of the Revenue

price"] and Section 92 (1) which states that any income arising from an international transaction shall be computed having regard to the ALP and Section 92C (1) which sets out the different methods of determining the ALP, makes it clear that the transfer

BAUSCH & LOMB EYECARE (INDIA) PVT. LTD.

The appeals of the Assessee are allowed and the appeals of the Revenue

price"] and Section 92 (1) which states that any income arising from an international transaction shall be computed having regard to the ALP and Section 92C (1) which sets out the different methods of determining the ALP, makes it clear that the transfer

DCIT, CC-29, NEW DELHI vs. DHARAMPAL SATYALPAL LTD., NEW DELHI

Bench: Shri G. S. Pannu & Shri Yogesh Kumar U.S.I.T.A. No. 1977/Del/2020 (A.Y 2014-15)

92 BA. 48. Above section provides that if eligible business receives any services/ goods from other units or business of assessee then if transaction value as recorded in books of account is not corresponding to market value of such goods or services on date of transfer then deduction u/s 80 IA shall be adjusted as a such transfer has been

ATEPL RAHEE JOINT VENTURE,NEW DELHI vs. ACIT CIRCLE-62(1), NEW DELHI

In the result, the appeal of the assessee stands allowed

Bench: Shri Shamim Yahya & Shri Anubhav Sharma[Assessment Year: 2015-16]

Price (ALP) of the specified domestic transaction is proposed by the TPO. She submitted that in this report, the method used under section 92(1) was stated to be ‘any other method as per Rule 10AB’. However, in the was stated to net margin method. Only on the basis of these facts, The AO has initiated penalty proceedings u/s 271AA

LG ELECTRONICS INDIA PRIVATE LIMITED ,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

In the result, the appeal of the revenue in ITA No

Bench: Shri Mahavir Singh & Shri M. Balaganesh

transfer pricing provisions contained in Chapter X of the Act, can be further supported by analysis of section 92(1

M/S LG ELECTRONICS INDIA PVT. LTD.,,NEW DELHI vs. DCIT, NOIDA

In the result, the appeal of the revenue in ITA No

Bench: Shri Mahavir Singh & Shri M. Balaganesh

transfer pricing provisions contained in Chapter X of the Act, can be further supported by analysis of section 92(1