(Now known as Sony India Limited)

Sections (1) and (2) to Section 92C are applicable to the assessed, as well as the Assessing Officer invoking power under Sub-Section (3) to Section 92C of the Act. As noted above, sub-section (2) to Section 92C stipulates that most appropriate method, out of the methods specified in sub-section (1) shall be applied to determine

COMMISSIONER OF INCOME TAX vs. AMADEUS INDIA PVT LTD

Appeal is dismissed

Transfer Pricing Officer by the Assessing Officer in this case. 14. Let us examine the relevant provisions of the said Act. Section 92 (1) of the said Act stipulates that any income arising from an international transaction shall be computed having regard to the arm’s length price. Section 92 B gives the meaning of an international transaction

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

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

LIUGONG INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeal of the assessee is partly allowed, as indicated above

Bench: Shri I.C. Sudhir & Shri L.P. Sahu

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

AMADEUS INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, ITA NO. 7691/Del/2017 stands allowed

Bench: Shri N.S. Saini & Shri Sudhanshu Srivastava

transfer pricing adjustment by substituting the arm's length price for the contract price. Section 92B defines 'international transaction' as under: '92B. Meaning of international transaction.—(1

AMADEUS INDIA PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, ITA NO. 7691/Del/2017 stands allowed

Bench: Shri N.S. Saini & Shri Sudhanshu Srivastava

transfer pricing adjustment by substituting the arm's length price for the contract price. Section 92B defines 'international transaction' as under: '92B. Meaning of international transaction.—(1

AMADEUS INDIA PVT. LTD.,NEW DELHI vs. ACIT, CIRCLE- 2(2), NEW DELHI

In the result, ITA NO. 7691/Del/2017 stands allowed

Bench: Shri N.S. Saini & Shri Sudhanshu Srivastava

transfer pricing adjustment by substituting the arm's length price for the contract price. Section 92B defines 'international transaction' as under: '92B. Meaning of international transaction.—(1

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

92B enterprise Transfer and the Pricing nature assessment country in Officer of year which it under business is resident section 92CA (3) ANNEXURE II Order under section 120, read with section 92CA of the Income-tax Act, 1961, dated April, 2003 In exercise of the power conferred by sub-section (1

CIT vs. CUSHMAN AND WAKEFIELD INDIA PVT LTD

The appeal is partly allowed

92B of the Income Tax Act, 1961 (“the Act”). Of these, two are important in the present proceedings: payment of referral fee of ₹ 1,73,26,631/- by the assessee to several foreign AEs for referring clients, and ₹ 1,06,39,865/- as reimbursement to CWS and CWHK for costs incurred by them for certain coordination and liaison services

LI & FUNG INDIA PVT LTD vs. COMMISSIONER OF INCOME TAX

The appeal is allowed and the order dated 25/11/11 of the ITAT Tribunal, Delhi Branch

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

92B one would have to in addition read the definition of “transaction” given in Section 92F(v). 27. Section 92C is the provision enabling determination of ALP. Section 92C (1) states that ALP in relation to an “international transaction could be determined by any of the methods provided in the said sub-section which is “most appropriate” having regard

M/S. NEW DELHI TELEVISION LTD.,NEW DELHI vs. ACIT, NEW DELHI

Bench: Shri H. S. Sidhu & Shri Prashant Maharishinew Delhi Television Ltd, Vs. Acit, 207, Okhla Industrial Estate, Phase- Circle-13(1), Iii, New Delhi New Delhi Pan: Aaacn0865D (Appellant) (Respondent) Acit, Vs. New Delhi Television Ltd, Circle-13(1), 207, Okhla Industrial Estate, New Delhi Phase-Iii, New Delhi Pan: Aaacn0865D (Appellant) (Respondent)

Pricing TPO e 92B the Officer of and countr under busin assess y section ess ment in 92CA year which (3) it is reside nt ANNEXURE II Order under section 120, read with section 92CA of the Income-tax Act, 1961, dated April, 2003 In exercise of the power conferred by sub-section (1) and sub-section (2) of section

DCIT, NEW DELHI vs. M/S. NEW DELHI TELEVISION LTD., NEW DELHI

Bench: Shri H. S. Sidhu & Shri Prashant Maharishinew Delhi Television Ltd, Vs. Acit, 207, Okhla Industrial Estate, Phase- Circle-13(1), Iii, New Delhi New Delhi Pan: Aaacn0865D (Appellant) (Respondent) Acit, Vs. New Delhi Television Ltd, Circle-13(1), 207, Okhla Industrial Estate, New Delhi Phase-Iii, New Delhi Pan: Aaacn0865D (Appellant) (Respondent)

Pricing TPO e 92B the Officer of and countr under busin assess y section ess ment in 92CA year which (3) it is reside nt ANNEXURE II Order under section 120, read with section 92CA of the Income-tax Act, 1961, dated April, 2003 In exercise of the power conferred by sub-section (1) and sub-section (2) of section

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

In the result, all the appeals of the assessee are treated as partly allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishi

1) of section 92B of the Act, it could be inferred that Transfer Pricing regulations would be applicable to any ‘transaction

M/S PEPSICO INDIA HOLDINGS PVT. LTD.,,GURGAON vs. ACIT,, NEW DELHI

In the result, all the appeals of the assessee are treated as partly allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishi

1) of section 92B of the Act, it could be inferred that Transfer Pricing regulations would be applicable to any ‘transaction

M/S PEPSICO INDIA HOLDINGS PVT. LTD.,,GURGAON vs. ACIT,, NEW DELHI

In the result, all the appeals of the assessee are treated as partly allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishi

1) of section 92B of the Act, it could be inferred that Transfer Pricing regulations would be applicable to any ‘transaction

M/S PEPSICO INDIA HOLDINGS PVT. LTD.,,GURGAON vs. ACIT,, NEW DELHI

In the result, all the appeals of the assessee are treated as partly allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishi

1) of section 92B of the Act, it could be inferred that Transfer Pricing regulations would be applicable to any ‘transaction

PEPSI FOODS PVT. LTD.,GURGAON vs. DCIT, NEW DELHI

In the result, all the appeals of the assessee are treated as partly allowed

Bench: Shri Amit Shukla & Shri Prashant Maharishi

1) of section 92B of the Act, it could be inferred that Transfer Pricing regulations would be applicable to any ‘transaction