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

The appeal is allowed

92D and after considering such evidence as the Transfer Pricing Officer may require on any specified points and after taking into account all relevant materials which he has gathered, the Transfer Pricing Officer shall, by order in writing, determine the arm's length price in relation to the international transaction [or specified domestic transaction] in accordance with sub-section (3

(Now known as Sony India Limited)

3) to Section 92D. (See judgment dated 16th December, 2013 in ITA No. 306/2012 titled Li & Fung India Pvt. Ltd. vs. Commissioner of Income Tax of the Delhi High Court). Five Methods 65. Comparable Uncontrolled Price Method (‗CUP Method‘, for short) compares price charged for the property or service in a controlled transaction with the price charged for comparable property

THE PR. COMMISSIONER OF INCOME TAX -4 vs. HEADSTRONG SERVICES INDIA PVT. LTD.

92D and after considering such evidence as the Transfer Pricing Officer may require on any specified points and after taking into account all relevant materials which he has gathered, the Transfer Pricing Officer shall, by order in writing, determine the arm‘s length price in relation to the international transaction [or specified domestic transaction] in accordance with sub-section (3

COMMISSIONER OF INCOME TAX-II vs. M/S LEROY SOMER & CONTROLS (INDIA) PVT. LTD

Transfer Pricing Officer (TPO) had issued first notice under Section 92CA(3) and 92D(3) of the Act seeking information

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

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.

Transfer Pricing Officer" means a Joint Commissioner or Deputy Commissioner or Assistant Commissioner authorised by the Board to perform all or any of the functions of an Assessing Officer specified in sections 92C and 92D in respect of any person or class of persons. 9. Sub-section (3

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

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

92D and after considering such evidence as the Transfer Pricing Officer may require on any specified points and after taking into account all relevant material which he has gathered, the Transfer Pricing Officer shall, by order in writing, determine the arm’s length price in relation to the international transaction in accordance with sub-section (3

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

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

92D and after considering such evidence as the Transfer Pricing Officer may require on any specified points and after taking into account all relevant material which he has gathered, the Transfer Pricing Officer shall, by order in writing, determine the arm’s length price in relation to the international transaction in accordance with sub-section (3

WRIGLEY INDIA PVT. LTD.,206, OKHLA INDUSTRIAL ESTATE, PHASE-3,NEW DELHI-110020 vs. DCIT, CIRCLE 27(2), NEW DELHI

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

3) of the Act\nare satisfied in the instant case;\n\n3. 2. disregarding the Arm's Length Price ('ALP') as determined by the Appellant in\nthe Transfer Pricing (\"TP') documentation maintained by it in terms of section 92D

DCIT, CIRCLE-25(1), NEW DELHI vs. WRIGLEY INDIA P.LTD, NEW DELHI

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

3) of the Act\nare satisfied in the instant case;\n3. 2. disregarding the Arm's Length Price ('ALP') as determined by the Appellant in\nthe Transfer Pricing (\"TP') documentation maintained by it in terms of section 92D

WRIGLEY INDIA PRIVATE LIMITED,DELHI vs. ACIT,CIRCLE-27(2), DELHI

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

3) of the Act\nare satisfied in the instant case;\n3. 2. disregarding the Arm's Length Price ('ALP') as determined by the Appellant in\nthe Transfer Pricing (\"TP') documentation maintained by it in terms of section 92D

DCIT, CIRCLE- 25(1), NEW DELHI vs. WRIGLEY INDIA PVT. LTD., NEW DELHI

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

3) of the Act\nare satisfied in the instant case;\n3. 2. disregarding the Arm's Length Price ('ALP') as determined by the Appellant in\nthe Transfer Pricing (\"TP') documentation maintained by it in terms of section 92D

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

Bench: Shri B. R. R. Kumar

3) An uncontrolled transaction shall be comparable to an international transaction [or a specified domestic transaction] if— (i) none of the differences, if any, between the transactions being compared, or between the enterprises entering into such transactions are likely to materially affect the price or cost charged or paid in, or the profit arising from, such transactions in the open

JCIT, CIRCLE-27(2), NEW DELHI vs. WRIGLEY INDIA PVT. LTD., NEW DELHI

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

3) of the Act\nare satisfied in the instant case;\n3. 2. disregarding the Arm's Length Price ('ALP') as determined by the Appellant in\nthe Transfer Pricing (\"TP') documentation maintained by it in terms of section 92D

DCIT, CIRCLE-25(1), NEW DELHI vs. WRIGLEY INDIA P.LTD, NEW DELHI

3) of the Act\nare satisfied in the instant case;\n3. 2. disregarding the Arm's Length Price ('ALP') as determined by the Appellant in\nthe Transfer Pricing (\"TP') documentation maintained by it in terms of section 92D

WRIGLEY INDIA PRIVATE LIMITED,DELHI vs. ACIT,CIRCLE-27(2), DELHI

3) of the Act\nare satisfied in the instant case;\n3. 2. disregarding the Arm's Length Price ('ALP') as determined by the Appellant in\nthe Transfer Pricing (\"TP') documentation maintained by it in terms of section 92D

AYATNA REALTY PVT. LTD.,NEW DELHI vs. ACIT, CIRCLE-3(2), NEW DELHI

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

Bench: Shri Vikas Awasthy & Shri Manish Agarwalm/S Wrigley India Private Dcit, Limited Circle-27(2), 206, Okhla Industrial Vs. New Delhi. Estate, Phase Iii, New Delhi-110020 Pan-Aaacw1789P (Appellant) (Respondent) Joint Cit (Osd), M/S Wrigley India Private Circle-27(2), Limited, New Delhi Vs. 206, Okhla Industrial Estate, Phase Iii, New Delhi-110020 Pan-Aaacw1789P (Appellant) (Respondent)

3) of the Act are satisfied in the instant case; 3.2. disregarding the Arm's Length Price ('ALP') as determined by the Appellant in the Transfer Pricing ("TP') documentation maintained by it in terms of section 92D

AYATNA REALTY PVT. LTD.,NEW DELHI vs. ACIT, CIRCLE-3(2), NEW DELHI

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

Bench: Shri Vikas Awasthy & Shri Manish Agarwalm/S Wrigley India Private Dcit, Limited Circle-27(2), 206, Okhla Industrial Vs. New Delhi. Estate, Phase Iii, New Delhi-110020 Pan-Aaacw1789P (Appellant) (Respondent) Joint Cit (Osd), M/S Wrigley India Private Circle-27(2), Limited, New Delhi Vs. 206, Okhla Industrial Estate, Phase Iii, New Delhi-110020 Pan-Aaacw1789P (Appellant) (Respondent)

3) of the Act are satisfied in the instant case; 3.2. disregarding the Arm's Length Price ('ALP') as determined by the Appellant in the Transfer Pricing ("TP') documentation maintained by it in terms of section 92D

GREENLAND FINANCE AND LEASING P. LTD.,DELHI vs. ITO, NEW DELHI

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

Bench: Shri Vikas Awasthy & Shri Manish Agarwalm/S Wrigley India Private Dcit, Limited Circle-27(2), 206, Okhla Industrial Vs. New Delhi. Estate, Phase Iii, New Delhi-110020 Pan-Aaacw1789P (Appellant) (Respondent) Joint Cit (Osd), M/S Wrigley India Private Circle-27(2), Limited, New Delhi Vs. 206, Okhla Industrial Estate, Phase Iii, New Delhi-110020 Pan-Aaacw1789P (Appellant) (Respondent)

3) of the Act are satisfied in the instant case; 3.2. disregarding the Arm's Length Price ('ALP') as determined by the Appellant in the Transfer Pricing ("TP') documentation maintained by it in terms of section 92D