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266 results for “transfer pricing”+ Section 92Cclear

Sorted by relevance

Mumbai409 Delhi266 Hyderabad56 Kolkata54 Bangalore49 Chennai36 Ahmedabad32 Pune22 Visakhapatnam11 Jaipur10 Indore8 Dehradun6 Surat4 Cochin3 Nagpur3 Cuttack3 Raipur2 Amritsar2 Panaji1 Guwahati1 Chandigarh1

Key Topics

Section 92C93 Transfer Pricing81 Section 143(3)74 Addition to Income73 Comparables/TP56 Disallowance34 Deduction30 Section 144C19 Section 92B18 Section 92C(3)

COMMISSIONER OF INCOME TAX vs. AMADEUS INDIA PVT LTD

Appeal is dismissed

ITA/938/2011HC Delhi28 Nov 2011

For Appellant: Ms Suruchi AggarwalFor Respondent: Mr M.S. Syali, Sr. Advocate with Mr Mayank Nagi &

Section 144CSection 260ASection 92BSection 92CSection 92E

section 92C to the Transfer Pricing Officer. (2) Where a reference is made under sub-section (1), the Transfer Pricing

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

In the result, the appeal of the Revenue is dismissed

Showing 1–20 of 266 · Page 1 of 14

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17

Section 92C(2)16

ITA 1058/DEL/2018[2008-09]Status: DisposedITAT Delhi07 Feb 2023AY 2008-09

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

For Appellant: Sh. G. C. Srivastava, Adv. &For Respondent: Sh. Bhagwati Charan, Sr. DR

Section 92C

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

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

The appeal is allowed

ITA/1114/2008HC Delhi04 Apr 2013

For Appellant: Ms Suruchii AggarwalFor Respondent: Mr M.S. Syali, Sr. Adv. with Ms Husnal Syali

Transfer Pricing Officer under section 92CA of the said Act for determination of the arm’s length price. At this juncture it would be relevant to note the provisions of section 92C

(Now known as Sony India Limited)

ITA/16/2014HC Delhi16 Mar 2015

section 92C to the Transfer Pricing Officer. (2) Where a reference is made under sub-section (1), the Transfer Pricing

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

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

ITA/110/2014HC Delhi11 Dec 2015

Section 260ASection 92C

92C. The fourth step would be to compare the price of the transaction that is shown to exist with the ALP and make the transfer pricing adjustment by substituting the ALP for the contract price. 63. A reading of the heading of Chapter X ["Computation of income from international transactions having regard to arm's length price"] and 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

ITA/710/2015HC Delhi11 Dec 2015

Section 260ASection 92C

92C. The fourth step would be to compare the price of the transaction that is shown to exist with the ALP and make the transfer pricing adjustment by substituting the ALP for the contract price. 63. A reading of the heading of Chapter X ["Computation of income from international transactions having regard to arm's length price"] and Section

M/S TAKATA INDIA PVT. LTD.,,NEW DELHI vs. DCIT, NEW DELHI

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

ITA 6835/DEL/2015[2011-12]Status: DisposedITAT Delhi28 Aug 2025AY 2011-12

Bench: Shri Prakash Chand Yadav & Manish Agarwalassessment Year: 2011-12 Takata India Pvt Ltd., Vs. Dcit, Circle 25(1), (Now Joyson Anand Abhishek New Delhi Safety Systems Pvt Ltd.,) Plot No.20, Sector-5, Imt Manesar, Gurugram (Haryana)-122050 Pan/Gir No. Aacct 7200 N (Appellant) .. ( Respondent)

For Appellant: NoneFor Respondent: Shri S.K.Jadhav, CIT (DR)

Transfer Pricing Officer) /Ld.DRP have erred in law and in facts and circumstances of the present case in not proving the benefit of deduction of +5% as per proviso to section 92C

ACIT, CIRCLE-8(1), NEW DELHI vs. EFS FACILITIES SERVICES (INDIA) PVT. LTD., NEW DELHI

In the result, both the appeals of the Revenue for assessment year

ITA 8347/DEL/2018[2014-15]Status: DisposedITAT Delhi11 Apr 2022AY 2014-15

Bench: Dr. B.R.R. Kumar & Ms. Astha Chandra

For Appellant: Shri Abhishek Jain, CAFor Respondent: Shri Sandeep Kumar Mishra, Sr. DR

section 92C to the Transfer Pricing Officer. (2) Where a reference is made under sub-section (1), the Transfer Pricing

ACIT, CIRCLE-8(1), NEW DELHI vs. EFS FACILITIES SERVICES (INDIA) PVT. LTD., NEW DELHI

In the result, both the appeals of the Revenue for assessment year

ITA 8346/DEL/2018[2013-14]Status: DisposedITAT Delhi11 Apr 2022AY 2013-14

Bench: Dr. B.R.R. Kumar & Ms. Astha Chandra

For Appellant: Shri Abhishek Jain, CAFor Respondent: Shri Sandeep Kumar Mishra, Sr. DR

section 92C to the Transfer Pricing Officer. (2) Where a reference is made under sub-section (1), the Transfer Pricing

ECOENERGY INSIGHTS LTD ( FORMERLY KNOWN AS CHUBB ALBA CONTROL SYSTEMS P.LTD),NEW DELHI vs. DCIT, CIRCLE-4(2), NEW DELHI

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

ITA 2321/DEL/2022[2018-19]Status: DisposedITAT Delhi10 Nov 2025AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaecoenergy Insights Ltd., Vs. Dcit, (Formerly Known As Chubb Alba Control Circle 4 (2), Systems P. Ltd.), New Delhi. Ground Floor, 18, Netaji Subhash Marg, Daryaganj, New Delhi – 110 002. (Pan :Aaaca0031C) (Appellant) (Respondent) Assessee By : Shri Nageshwar Rao, Advocate Shri Parth, Advocate Shri Pratik Rath, Advocate Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 12.08.2025 Date Of Order : 10.11.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Assessment Order Dated 25.07.2022Passed By The Assessment Unit, Income Tax Department Under Section 147 Read With Section 144C(13) R.W.S. 144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Ay 2018-19 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act.

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Shri S.K. Jadhav, CIT DR

Section 143(2)Section 144C(13)Section 144C(5)Section 147Section 92C

section 92C to the Transfer Pricing Officer. (10) …….…. Explanation.—For the purposes of this section, "Transfer Pricing Officer" means a Joint

HEADSTRONG SERVICES INDIA PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal of the assessee stands partly allowed for statistical purposes in terms of our observations contained in the preceding paragraphs

ITA 508/DEL/2017[2012-13]Status: DisposedITAT Delhi17 Mar 2022AY 2012-13

Bench: Shri B. R. R. Kumar

Section 143(3)Section 144C(13)Section 144C(5)Section 92BSection 92C

section 92C, the arm's length price in relation to an international transaction [or a specified domestic transaction] shall be determined by any of the following methods, being the most appropriate method, in the following manner, namely :— (a) comparable uncontrolled price method, by which,— (i) the price charged or paid for property transferred

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

ITA 430/DEL/2024[2006-07]Status: DisposedITAT Delhi15 Oct 2025AY 2006-07

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

92C. The fourth step would be to compare the price of the transaction that is shown to exist with that of the ALP and make the TP adjustment by substituting the ALP for the contract price. XXX 34. The TP adjustment is not expected to be made by deducing from the difference between the 'excessive' AMP expenditure incurred

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

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

ITA 991/DEL/2016[2011-12]Status: DisposedITAT Delhi15 Oct 2025AY 2011-12

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

92C. The fourth step would be to compare the price of the transaction that is shown to exist with that of the ALP and make the TP adjustment by substituting the ALP for the contract price. XXX 34. The TP adjustment is not expected to be made by deducing from the difference between the 'excessive' AMP expenditure incurred

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

ITA 9000/DEL/2019[2014-15]Status: DisposedITAT Delhi15 Oct 2025AY 2014-15

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

92C. The fourth step would be to compare the price of the transaction that is shown to exist with that of the ALP and make the TP adjustment by substituting the ALP for the contract price. XXX 34. The TP adjustment is not expected to be made by deducing from the difference between the 'excessive' AMP expenditure incurred

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

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

ITA 2035/DEL/2021[2007-08]Status: DisposedITAT Delhi15 Oct 2025AY 2007-08

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

92C. The fourth step would be to compare the price of the transaction that is shown to exist with that of the ALP and make the TP adjustment by substituting the ALP for the contract price. XXX 34. The TP adjustment is not expected to be made by deducing from the difference between the 'excessive' AMP expenditure incurred

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

ITA 433/DEL/2024[2005-06]Status: DisposedITAT Delhi15 Oct 2025AY 2005-06

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

92C. The fourth step would be to compare the price of the transaction that is shown to exist with that of the ALP and make the TP adjustment by substituting the ALP for the contract price. XXX 34. The TP adjustment is not expected to be made by deducing from the difference between the 'excessive' AMP expenditure incurred

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

ITA 7424/DEL/2018[2013-14]Status: DisposedITAT Delhi15 Oct 2025AY 2013-14

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

92C. The fourth step would be to compare the price of the transaction that is shown to exist with that of the ALP and make the TP adjustment by substituting the ALP for the contract price. XXX 34. The TP adjustment is not expected to be made by deducing from the difference between the 'excessive' AMP expenditure incurred

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

ITA 1267/DEL/2020[2007-08]Status: DisposedITAT Delhi15 Oct 2025AY 2007-08

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

92C. The fourth step would be to compare the price of the transaction that is shown to exist with that of the ALP and make the TP adjustment by substituting the ALP for the contract price. XXX 34. The TP adjustment is not expected to be made by deducing from the difference between the 'excessive' AMP expenditure incurred

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

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

ITA 1969/DEL/2016[2011-12]Status: DisposedITAT Delhi15 Oct 2025AY 2011-12

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

92C. The fourth step would be to compare the price of the transaction that is shown to exist with that of the ALP and make the TP adjustment by substituting the ALP for the contract price. XXX 34. The TP adjustment is not expected to be made by deducing from the difference between the 'excessive' AMP expenditure incurred

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

ITA 6838/DEL/2017[2012-13]Status: DisposedITAT Delhi15 Oct 2025AY 2012-13

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

92C. The fourth step would be to compare the price of the transaction that is shown to exist with that of the ALP and make the TP adjustment by substituting the ALP for the contract price. XXX 34. The TP adjustment is not expected to be made by deducing from the difference between the 'excessive' AMP expenditure incurred