MUFG BANK,LTD (EARLIER KNOWN AS THE BANK OF TOKYO MITSUBISHI UFJ LTD.),NEW DELHI vs. ACIT, CIRCLE-2(2)(1) INT. TAXATION, DELHI

In the result, the appeal of the assessee is allowed in above terms

Bench: Shri Pradip Kumar Kedia & Shri Narender Kumar Choudhry

transfer pricing order wherein the Id. TPO has discussed the TP analysis made by the taxpayer to benchmark its international transactions including transaction of receipt of guarantee commissions by the taxpayer as a bundled transactions but the Id. TPO declined to accept the contention raised by the taxpayer that all the international transactions of taxpayer are to be benchmarked

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

TP). The order should contain details of the data used, reasons for arriving at a certain price and the applicability of methods. It may be emphasized that the application of method including the application of the most appropriate method, the data used, factors governing the applicability of respective methods, computation of price under a given method will all be subjected

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

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

methods of determining the ALP, makes it clear that the transfer pricing adjustment is made by substituting the ALP for the price of the transaction. To begin with there has to be an international transaction with a certain disclosed price. The transfer pricing adjustment envisages the substitution of the price of such international transaction with the ALP. 64. The 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

methods of determining the ALP, makes it clear that the transfer pricing adjustment is made by substituting the ALP for the price of the transaction. To begin with there has to be an international transaction with a certain disclosed price. The transfer pricing adjustment envisages the substitution of the price of such international transaction with the ALP. 64. The transfer

RAMPGREEN SOLUTIONS PVT LTD vs. COMMISSIONER OF INCOME TAX

The appeal is allowed

Bench: The Tribunal, Impugning The Assessment Order Passed By The Assessing Officer (Hereafter ‘Ao’) Making The Transfer Pricing Adjustments (Hereafter ‘Tp Adjustments’) In Respect Of The Assessment Year (Hereafter ‘Ay’) 2008-09 As Finalised By The Transfer Pricing Officer 2015:Dhc:6421-Db

method for the purposes of benchmarking the international transaction. The Assessee’s operating profit margin (i.e. operating profit/total cost) was computed at 14.83% and the Assessee claimed that the same was comparable with other companies rendering voice call services. For the purposes of the transfer pricing study, the Assessee chose eight comparable entities and the arithmetic average of the operating

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

Transfer Pricing Policy of the group, AEs and same were not furnished (para 2.8.1 of TP order) This non-compliance from the side of assessee was specifically highlighted by the undersigned during the course of hearing, as it prevented the TPO from examining the factual aspect relevant to the issue, therefore such non-compliance should be viewed adversely against

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

Transfer Pricing Policy of the group, AEs and same were not furnished (para 2.8.1 of TP order) This non-compliance from the side of assessee was specifically highlighted by the undersigned during the course of hearing, as it prevented the TPO from examining the factual aspect relevant to the issue, therefore such non-compliance should be viewed adversely against

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

Transfer Pricing Policy of the group, AEs and same were not furnished (para 2.8.1 of TP order) This non-compliance from the side of assessee was specifically highlighted by the undersigned during the course of hearing, as it prevented the TPO from examining the factual aspect relevant to the issue, therefore such non-compliance should be viewed adversely against

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

Transfer Pricing Policy of the group, AEs and same were not furnished (para 2.8.1 of TP order) This non-compliance from the side of assessee was specifically highlighted by the undersigned during the course of hearing, as it prevented the TPO from examining the factual aspect relevant to the issue, therefore such non-compliance should be viewed adversely against

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

Transfer Pricing Policy of the group, AEs and same were not furnished (para 2.8.1 of TP order) This non-compliance from the side of assessee was specifically highlighted by the undersigned during the course of hearing, as it prevented the TPO from examining the factual aspect relevant to the issue, therefore such non-compliance should be viewed adversely against

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

Transfer Pricing Policy of the group, AEs and same were not furnished (para 2.8.1 of TP order) This non-compliance from the side of assessee was specifically highlighted by the undersigned during the course of hearing, as it prevented the TPO from examining the factual aspect relevant to the issue, therefore such non-compliance should be viewed adversely against

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

Transfer Pricing Policy of the group, AEs and same were not furnished (para 2.8.1 of TP order) This non-compliance from the side of assessee was specifically highlighted by the undersigned during the course of hearing, as it prevented the TPO from examining the factual aspect relevant to the issue, therefore such non-compliance should be viewed adversely against

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

Transfer Pricing Policy of the group, AEs and same were not furnished (para 2.8.1 of TP order) This non-compliance from the side of assessee was specifically highlighted by the undersigned during the course of hearing, as it prevented the TPO from examining the factual aspect relevant to the issue, therefore such non-compliance should be viewed adversely against

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

Transfer Pricing Policy of the group, AEs and same were not furnished (para 2.8.1 of TP order) This non-compliance from the side of assessee was specifically highlighted by the undersigned during the course of hearing, as it prevented the TPO from examining the factual aspect relevant to the issue, therefore such non-compliance should be viewed adversely against

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.

Method 0 TOTAL 4600756532 3 4. After considering the TP study submitted by the assessee, the TPO applied various filters to benchmark each international transactions and proposed following TP adjustments :- Sl. No. Particulars Amount 1. Purchase of goods 2,56,08,980 2. Transfer of specified assets 39,00,60,000 3. Receipt

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 adjustment on account of payment of management service fee. 11. We have heard the rival submission and perused the material available on record. During the course of TP assessment proceedings the Ld. TPO held that the assessee could not submit any evidence that management support services had actually been received and also failed to demonstrate the need

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 adjustment on account of payment of management service fee. 11. We have heard the rival submission and perused the material available on record. During the course of TP assessment proceedings the Ld. TPO held that the assessee could not submit any evidence that management support services had actually been received and also failed to demonstrate the need

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

methods specified in section 92C of the Act. The fourth step would be to compare the price of the international transaction with the comparables and make transfer pricing adjustment by substituting the arm's length price for the contract price, wherever required. In respect of AMP expenses, the Hon'ble High Court held that the Revenue first arrived