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

price as database of the reference reference of the transaction associate section to the determined adopted order of from tax as per d 92A taxpayer taxpayer by the by TPO the A.O. A.O. payer section 92B enterprise Transfer

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

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

92B to 92F, the sine qua non for commencing the transfer pricing exercise is to show the existence of an international transaction. The next step is to determine the price of such transaction. The third step would be to determine the ALP by applying one of the five price discovery methods specified in Section

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

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

92B to 92F, the sine qua non for commencing the transfer pricing exercise is to show the existence of an international transaction. The next step is to determine the price of such transaction. The third step would be to determine the ALP by applying one of the five price discovery methods specified in Section

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

Transfer Pricing Regulations. 9. The Ld. Counsel highlighted that the alleged AMP expenses incurred by the Appellant do not constitute an international transaction under the provisions of the Act since section 92B

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

Transfer Pricing Regulations. 9. The Ld. Counsel highlighted that the alleged AMP expenses incurred by the Appellant do not constitute an international transaction under the provisions of the Act since section 92B

LG ELECTRONICS INDIA PVT. LTD.,NEW DELHI vs. ADDL. CIT, SPECIAL RANGE- 5, NEW DELHI

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

price protection Rs. 39,23,45,128/- d. shop, sales, execution, remuneration Rs. 125,53,76,689/- e. trade discount on invoices Rs. 1658,73,81,046/- Total Rs. 1200,72,66,766/- 5.5 The ld TPO sought to treat the AMP expenses as an international transaction within the meaning of Section 92B of the Act. For this purposes

DCIT, NOIDA vs. M/S. L.G. ELECTRONICS INDIA PVT. LTD., GREATER NOIDA

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

price protection Rs. 39,23,45,128/- d. shop, sales, execution, remuneration Rs. 125,53,76,689/- e. trade discount on invoices Rs. 1658,73,81,046/- Total Rs. 1200,72,66,766/- 5.5 The ld TPO sought to treat the AMP expenses as an international transaction within the meaning of Section 92B of the Act. For this purposes

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

price protection Rs. 39,23,45,128/- d. shop, sales, execution, remuneration Rs. 125,53,76,689/- e. trade discount on invoices Rs. 1658,73,81,046/- Total Rs. 1200,72,66,766/- 5.5 The ld TPO sought to treat the AMP expenses as an international transaction within the meaning of Section 92B of the Act. For this purposes

LG ELECTRONICS INDIA PRIVATE LIMITED,MATHURA ROAD, 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

price protection Rs. 39,23,45,128/- d. shop, sales, execution, remuneration Rs. 125,53,76,689/- e. trade discount on invoices Rs. 1658,73,81,046/- Total Rs. 1200,72,66,766/- 5.5 The ld TPO sought to treat the AMP expenses as an international transaction within the meaning of Section 92B of the Act. For this purposes

DCIT, CIRCLE-13(1), NEW DELHI vs. LG ELECTRONICS INDIA PVT. LTD., DELHI

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

price protection Rs. 39,23,45,128/- d. shop, sales, execution, remuneration Rs. 125,53,76,689/- e. trade discount on invoices Rs. 1658,73,81,046/- Total Rs. 1200,72,66,766/- 5.5 The ld TPO sought to treat the AMP expenses as an international transaction within the meaning of Section 92B of the Act. For this purposes

LG ELECTRONICS INDIA PVT. LTD.,NEW DELHI vs. DCIT, CIRCLE-15(2), NEW DELHI

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

price protection Rs. 39,23,45,128/- d. shop, sales, execution, remuneration Rs. 125,53,76,689/- e. trade discount on invoices Rs. 1658,73,81,046/- Total Rs. 1200,72,66,766/- 5.5 The ld TPO sought to treat the AMP expenses as an international transaction within the meaning of Section 92B of the Act. For this purposes

LG ELECTRONICS INDIA PVT. LTD.,NEW DELHI vs. ADDL. CIT, SPECIAL RANGE- 5, NEW DELHI

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

price protection Rs. 39,23,45,128/- d. shop, sales, execution, remuneration Rs. 125,53,76,689/- e. trade discount on invoices Rs. 1658,73,81,046/- Total Rs. 1200,72,66,766/- 5.5 The ld TPO sought to treat the AMP expenses as an international transaction within the meaning of Section 92B of the Act. For this purposes

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

price protection Rs. 39,23,45,128/- d. shop, sales, execution, remuneration Rs. 125,53,76,689/- e. trade discount on invoices Rs. 1658,73,81,046/- Total Rs. 1200,72,66,766/- 5.5 The ld TPO sought to treat the AMP expenses as an international transaction within the meaning of Section 92B of the Act. For this purposes

DCIT, CIRCLE-15(2), NEW DELHI vs. LG ELECTRONICS INDIA PVT. LTD., NEW DELHI

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

Bench: Shri Mahavir Singh & Shri M. Balaganesh

price protection Rs. 39,23,45,128/- d. shop, sales, execution, remuneration Rs. 125,53,76,689/- e. trade discount on invoices Rs. 1658,73,81,046/- Total Rs. 1200,72,66,766/- 5.5 The ld TPO sought to treat the AMP expenses as an international transaction within the meaning of Section 92B of the Act. For this purposes

BAUSCH & LOMB EYECARE (INDIA) PVT. LTD.

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

transfer pricing adjustment envisages the substitution of the price of such international transaction with the ALP. 54. Under Sections 92B

BAUSCH & LOMB EYECARE (INDIA) PVT. LTD.

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

transfer pricing adjustment envisages the substitution of the price of such international transaction with the ALP. 54. Under Sections 92B

BAUSCH & LOMB EYECARE (INDIA) PVT. LTD.

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

transfer pricing adjustment envisages the substitution of the price of such international transaction with the ALP. 54. Under Sections 92B

BAUSCH & LOMB EYECARE (INDIA) PVT. LTD.

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

transfer pricing adjustment envisages the substitution of the price of such international transaction with the ALP. 54. Under Sections 92B