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

Bench: Shri G. S. Pannu & Shri Yogesh Kumar U.S.I.T.A. No. 1976/Del/2020 (A.Y 2013-14)

price, which are, further transferred to eligible units at actual cost comprising of procurement cost, processing cost, freight expenses on FIFO [ 1st in 1st out] basis. Therefore, it was stated that assessee has transferred goods at total cost comprising all these cost components. Merely because silver for is also sold by appellant to third-party customers at a price higher

PEPSICO INDIA HOLDINGS PVT. LTD.,GURGAON vs. ACIT, CENTRAL CIRCLE-7, NEW DELHI

In the result, the appeal of the assessee is allowed and the Stay

Bench: Shri Shamim Yahya & Ms. Astha Chandra[Assessment Year: 2018-19]

920,27,38,000/-. The Transfer pricing Officer vide an order dated 31.10.2019, held that since incurring of the said AMP expenses by the assessee had also benefitted the AEs thereby promoting their brands and trademark, the assessee had essentially incurred cost in connection with the services it provided to the AEs under a mutual arrangement, which although not reduced

SWATCH GROUP (INDIA) PRIVATE LIMITED,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 22(2), C.R. BUILDING

In the result, the appeal of the assessee is partly allowed

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh[Assessment Year: 2021-22] Swatch Group (India) Private Deputy Commissioner Of Income Limited, Tax, 4Th Floor, Rectangle-I, Plot No. D- Vs Circle 22(2), 4, Saket District Centre, C.R. Building, I.P. Estate, Delhi, New Delhi-110017. 110002. Pan- Aafcs7516R Assessee Revenue

920/- the above proposal 8. Aggrieved with the said order, the assessee filed its objections before the Ld. DRP. The Ld. DRP vide its order dated 09.09.2024, upheld the finding of the AO, and the relevant directions of the Ld. DRP in para no. 7.3 and 7.3.1 at page nos. 31 to 34 of its order (placed

HONDA SIEL POWER PRODUCTS LIMITED vs. DEPUTY COMMISSIONER OF INCOME TAX

The appeal is allowed but in the circumstances no orders as to

920 TNMM 4. The Assessee filed its return of income for the AY in question on 30th September, 2008, declaring a total income of Rs. 37,15,72,026. The return was picked up for scrutiny and notices under Sections 143(2) and 142(1) of the Income Tax Act, 1961 (‘Act’) were issued. During the course of the assessment

DCIT, NEW DELHI vs. M/S. EXXON MOBIL LUBRICANTS PVT. LTD., NEW DELHI

In the result, appeal of the Revenue is party allowed

transfer pricing regulations requires\neach international transaction to be evaluated and analyzed separately. With\nrespect to the same, the Respondent wish to draw attention of the Hon'ble\nTribunal towards the specific provision contained in sub rule 1 of Rule 100C.\n\"(1) For the purposes of sub-section (1) of section 920

SONY INDIA PVT. LTD.,NEW DELHI vs. NATIOANAL E- ASSESMENT CENTRE, NEW DELHI

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

Bench: Shri Chandra Mohan Garg & Shri N.K. Billaiya

920 xi. Purchase of Samples TNMM OP/OR 15,735,124 xii. Reimbursement Paid by SID to its TNMM OP/OR 8,941,313 AEs xiii. Provision of advisory services TNMM OP/OC 21,349,094 xiv. Reimbursement received by SID Other NA 162,176,641 from its AEs Method XV. Receipt of Call Centre Services TNMM OP/OR 45,586,198 xvi. Receipt

TREND MICRO INDIA PRIVATE LIMITED,NEW DELHI vs. ACIT, CIRCLE-25(2), NEW DELHI

The appeal is allowed

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaassessment Year: 2013-14 Trend Micro India Private Limited, Vs Acit, 10Th Floor, Eros Corporate Tower, Circle-25(2), Nehru Place, New Delhi. New Delhi. Pan: Aacct2082Q (Appellant) (Respondent) Assessee By : Shri Vishal Kalra, Advocate & Shri S.S. Tomar, Advocate Revenue By : Shri Amit Katoch, Sr. Dr Date Of Hearing : 27.03.2024 Date Of Pronouncement : 31.05.2024

transfer pricing was forwarded to TPO and he made certain adjustments by increasing the amount of Rs. 1,49,29,635/- by applying the TNMM Method treating the most appropriate method. While enhancing the valuation, he made comparable analysis of operating profit/operating cost (OP/OC) as the profit level indicator of 10 companies by rejecting 05 comparable companies identified by appellant

MITSUI PRIME ADVANCED COMPOSITES INDIA PVT. LTD.,GURGAON vs. DCIT CIRCLE-16(*2), NEW DELHI

In the result, the appeal filed by the assessee is allowed

Bench: Dr. B. R. R. Kumar & Sh. Yogesh Kumar Usi.T.A. No. 6944/Del/2019 (A.Y 2013-14)

Section 143(3)/144C(3) r.w.s 92CA(3) of the Act at an assessed income of INR 15,24,58,920/- [addition on account of Transfer pricing

AMWAY INDIA ENTERPRISES PRIVATE LIMITED,NEW DELHI vs. DCIT, CIRCLE 1(1), DELHI / NFAC, DELHI

Appeal of the assessee is allowed

Bench: Shri Sudhir Pareek & Shri Manish Agarwalamway India Enterprises Private Dcit, Limited, Circle-1(1), Ground Floor, Elegance Tower, Vs. Delhi/Nfac. Plot No.8, Non Hierarchical Commercial, Jasola, Delhi-110025. Pan-Aaaca5603Q (Appellant) (Respondent)

920 read with Rate 100 of the Income Tax Rules, 1962 ("Rules") without assigning any cogent reasons and hiss further erred is proposing aforesaid transfer pricing adjustment in gross disregard of the transfer pricing regulations. 9. The Ld. TPO/AO/DRP has erred on facts and in law in holding AMP expense incurred by the assessee as an international transaction under section

LOUIS VUITTON INDIA RETAIL PRIVATE LIMITED,GURGAON vs. DCIT CIRCLE-1(1), GURGAON

In the result, the Appeal of the Assessee is partly allowed

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishra(Ita No. 4348/Del/2024 (A.Y. 2020-21) Louis Vuitton India Vs. Dcit Retail Private Limited Circle-1(1) 901-A, 9Th Floor, Time Gurgaon, Tower, Mg Road, Haryana Gurgaon, Haryana Pan: Aaacl8230E Appellant Respondent

Section 144B of the Act by making TP adjustment of Rs. 4,34,45,060/-. Aggrieved by the final assessment order dated 23/07/2024, the Assessee preferred the present Appeal on the Grounds mentioned above. 4. Ground No. 1 & 2 are general in nature and Ground No. 5 of the Assessee’s Appeal has been not pressed. Hence, Ground

COMPUNNEL TECHNOLOGY INDIA (P) LTD,NOIDA vs. ACIT CIRCLE-4(2), NEW DELHI

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Challa Nagendra Prasad & Shri Amitabh Shukla[Assessment Year:2016-17] Compunnel Technology India Assistant Commissioner Of Income Private Limited, Tax, Circle-4(2), C-4, Sector-58, Noida, Vs New Delhi Uttar Pradesh-201301 Pan Aaaci5095A Appellant Respondent Assessee By Shri Dinesh Gupta, Ar Revenue By Shri Dharm Veer Singh, Cit(Dr) Date Of Hearing 15.12.2025 Date Of Pronouncement 15.12.2025

920/-. The learned Transfer Pricing Officer made adjustments in as much as against, CUP method adopted by assessee it choose, to opt for TNMM for his TP study. The ld. DRP partly confirmed the draft assessment order, leading to determination of taxable income of Rs.7,59,14,326/- vide order under section

ROCKWELL AUTOMATION INDIA PRIVATE LIMITED,DELHI vs. DCIT CIRCLE-19(1), DELHI

Appeal is partly allowed for statistical purposes

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalrockwell Automation India Deputy Commissioner Of Private Limited, Income Tax, Circle-19(1), Registered Address: 131, Vs. Delhi. Functional Industrial Are, Patparganj, Delhi-110092 Communication Address: 131, Functional Industrial Area, Patparganj, New Delhi. Pan-Aaccr3791A (Appellant) (Respondent) Assessee By Shri Ajit Jain, Ar Department By Shri Dharm Veer Singh, Cit-Dr Date Of Hearing 19.08.2025 Date Of Pronouncement 17.11.2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Final Assessment Order Passed U/S 143(3) R.W.S 144C (13) Read With Section 144B Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’) Dated 30.07.2024 For Assessment Year 2020-21. 2. Brief Facts Of The Case Ae That The Assessee Is A Company Engaged In The Business Of Manufacturing / Assembling Of Automation & Industrial Control Products / Systems. The Case Was Selected For Scrutiny & A Reference Was Made To The Tpo Due With Transactions With Ae’S. The Return Of Income Was Filed On Rockwell Automation India Private Limited Vs. Dcit 15.02.2021 Declaring Total Income At Rs.97,08,46,360/-. The Tpo Vide Its Order Dated 28.07.2023 Passed U/S 92Ca(3) Of The Act Has Proposed Adjustments Totaling To Rs. 26,12,44,668/-. Thereafter, The Ao Has Passed The Draft Assessment Order U/S 144C(1) Of The Act Dated 27.09.2023 Wherein The Ao Has Proposed The Additions Towards The Tp Adjustment As Per Tpo’S Order & Proposed To Assess The Total Income Of The Assessee At Rs.19,88,57,458/- & Further Proposed To Disallow Relief Claimed U/S 90/90A At Rs.1,04,60,287/-. Against The Draft Assessment Order, The Assessee Filed Objections Before The Drp.

Transfer Pricing (TP) documentation, modifying the same with his own analysis and is doing 6.1 erred in not appreciating that none of the conditions set out in section 920

BORGWARNER EMISSIONS SYSTEMS INDIA PRIVATE LIMITED,NEW DELHI vs. DCIT, CIRCLE-4(2), DELHI

Appeal is allowed

Bench: Shri Pradip Kumar Kedia & Shri Narinder Kumar

Transfer Pricing Officer observed that no changes were required, as per directions issued by DRP. That is how, vide order dated 19.7.2022, the TPO gave effect to the directions issued by DRP. Ultimately, vide impugned final assessment order dated 28.7.2022, adjustment of Rs.9,09,41,198/-came to be added to the total income of the assessee, in addition

MAVENIR INDIA PVT. LTD. (EARLIER KNOWN AS COMVERSE NETWORK SYSTEM INDIA PVT. LTD.),GURGAON vs. DCIT, CIRCLE- 3(1), GURGOAN

In the result, the appeal is partly allowed

Bench: Shri Saktijit Dey & Shri Anadee Nath Misshrar Assessment Year: 2016-17

Transfer Pricing (‘TP’) documentation maintained by it in terms of Section 92D of the Act read with Rule 10D of the Income Tax Rules, 1962 (‘the Rules’); 3.2. rejecting comparability analysis undertaken by the Appellant in the TP documentation and in conducting a fresh comparability analysis based on application of the additional/ revised filters in determining

BMW INDIA FINANCIAL SERVICES PRIVATE LIMITED,GURGAON vs. DCIT, CIRCLE-10(1), DELHI

In the result, the appeals of the assessee are allowed

Bench: Sh. C. N. Prasaddr. B. R. R. Kumarita No. 478/Del/2022 : Asstt. Year : 2017-18 Ita No. 562/Del/2022 : Asstt. Year : 2018-19 Bmw India Financial Services Pvt. Ltd., Vs Dcit, 1St Floor, Building No. 11, The Oberoi Circle-10(1), Corporate Tower, Dlf Cyber City, Delhi Phase-2, Gurgaon, Haryana-122002 (Appellant) (Respondent) Pan No. Aadcb8986G Assessee By : Sh. Ajit Jain, Ca Revenue By : Sh. Rajesh Kumar, Cit Dr Date Of Hearing: 01.02.2023 Date Of Pronouncement: 03.02.2023

transfer pricing adjustment as INR 6,367,777 amounting to INR 5,685,515. Pertaining to Corporate Tax Matters 7 On the facts and circumstances of the case, the Ld. AO has grossly erred in computing the total income of INR 95,78,78,570 (as against INR 94,35,93,680) in the Final assessment order dated 18 January

BMW INDIA FINANCIAL SERVICES P.LTD,GURUGRAM vs. DCIT, CIRCLE-1(1), NEW DELHI

In the result, the appeals of the assessee are allowed

Bench: Sh. C. N. Prasaddr. B. R. R. Kumarita No. 478/Del/2022 : Asstt. Year : 2017-18 Ita No. 562/Del/2022 : Asstt. Year : 2018-19 Bmw India Financial Services Pvt. Ltd., Vs Dcit, 1St Floor, Building No. 11, The Oberoi Circle-10(1), Corporate Tower, Dlf Cyber City, Delhi Phase-2, Gurgaon, Haryana-122002 (Appellant) (Respondent) Pan No. Aadcb8986G Assessee By : Sh. Ajit Jain, Ca Revenue By : Sh. Rajesh Kumar, Cit Dr Date Of Hearing: 01.02.2023 Date Of Pronouncement: 03.02.2023

transfer pricing adjustment as INR 6,367,777 amounting to INR 5,685,515. Pertaining to Corporate Tax Matters 7 On the facts and circumstances of the case, the Ld. AO has grossly erred in computing the total income of INR 95,78,78,570 (as against INR 94,35,93,680) in the Final assessment order dated 18 January

MDEVERYWHERE INDIA PVT. LTD.,NOIDA vs. DCIT, CIRCLE- 6(1), NEW DELHI

In the result, appeal of the Assessee is partly allowed and appeal of the Revenue is dismissed

Bench: R.K. Panda & Shri Ms. Astha Chandra

transfer prices of its international related party transactions. 4. That the Ld. CIT(A) grossly erred in law and on facts by confirming the action of the Ld TPO/AO of denying the benefit of (+/ -) 5 percent [as mentioned in the proviso to section 920

DCIT, CIRCLE- 6(1), NEW DELHI vs. MDEVERYWHERE INDIA PVT. LTD., NOIDA

In the result, appeal of the Assessee is partly allowed and appeal of the Revenue is dismissed

Bench: R.K. Panda & Shri Ms. Astha Chandra

transfer prices of its international related party transactions. 4. That the Ld. CIT(A) grossly erred in law and on facts by confirming the action of the Ld TPO/AO of denying the benefit of (+/ -) 5 percent [as mentioned in the proviso to section 920