M/S. AGRAWAL COAL CORPORATION P. LTD.,INDORE vs. THE DCIT RANGE 1(1), INDORE

Bench: Shri D.T. Garasia & Shri O.P. Meena

Transfer Pricing Adjustments 1. Ground No.1-Addition made while computing arm’s length price for provision of corporate guarantee by appellant

THE DCIT-1(1), INDORE vs. M/S. AGRAWAL COAL CORPORATION P. LTD., INDORE

Bench: Shri D.T. Garasia & Shri O.P. Meena

Transfer Pricing Adjustments 1. Ground No.1-Addition made while computing arm’s length price for provision of corporate guarantee by appellant

M/S. AGRAWAL COAL CORPORATION P. LTD.,INDORE vs. THE DCIT -CIRCLE 1(1), INDORE

Bench: Shri D.T. Garasia & Shri O.P. Meena

Transfer Pricing Adjustments 1. Ground No.1-Addition made while computing arm’s length price for provision of corporate guarantee by appellant

COMPUTER SCIENCES CORPORATION INDIA PRIVATE LIMITED,CHENNAI vs. ACIT, CHENNAI

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2007-08 Computer Sciences Acit, Corporation India Private Company Circle 1(3), Limited, Chennai [Formerly Covansys (India) Private Limited], बनाम/ Unit 13, Block 2, Sdf Buildings, Vs. Madras Export Processing Zone, Tambaram, Chennai (Assessee / Appellant) (Revenue / Respondent) Pan: Aaacc1351M Assessee By Shri Neeraj Jain, Adv. Shri Abhishek Agrawal, Ca Revenue By Shri P.K. Mishra, Cit Dr Date Of Hearing 12.07.2023 Date Of Pronouncement

Transfer Pricing Officer (TPO) to determine the arm length price (ALP) of those transactions. Vide order dated 26.10.2010 passed u/s 92CA

M/S. ANDRITZ HYDRO PRIVATE LIMITED (EARLIER KNOWN AS VA TECH HYDRO INDIA PRIVATE LIMITED),BHOPAL vs. THE DCIT 1(1), BHOPAL

In the result, grounds taken by the assessee in all the years with respect to provision of warranty are allowed

Bench: Shri D.T. Garasia & Shri O.P. Meena

Transfer Pricing Grounds 1. The Learned Transfer Pricing Officer (Ld. TPO)/ Dispute Resolution Panel (DRP) erred on the facts and circumstances

THE DCIT, 1(1), BHOPAL vs. M/S. ANDRITZ HYDRO PVT. LTD., RAISEN

In the result, grounds taken by the assessee in all the years with respect to provision of warranty are allowed

Bench: Shri D.T. Garasia & Shri O.P. Meena

Transfer Pricing Grounds 1. The Learned Transfer Pricing Officer (Ld. TPO)/ Dispute Resolution Panel (DRP) erred on the facts and circumstances

M/S ANDRITZ HYDRO PRIVATE LIMITED (EARLIER KNOWN AS V A TECH HYDRO INDAI PVT. LTD.),MANDIDEEP vs. THE ACIT 1(1), BHOPAL

In the result, grounds taken by the assessee in all the years with respect to provision of warranty are allowed

Bench: Shri D.T. Garasia & Shri O.P. Meena

Transfer Pricing Grounds 1. The Learned Transfer Pricing Officer (Ld. TPO)/ Dispute Resolution Panel (DRP) erred on the facts and circumstances

THE ACIT, 1(1), BHOPAL vs. M/S. ANDRITZ HYDRO PVT. LTD., RAISEN

In the result, grounds taken by the assessee in all the years with respect to provision of warranty are allowed

Bench: Shri D.T. Garasia & Shri O.P. Meena

Transfer Pricing Grounds 1. The Learned Transfer Pricing Officer (Ld. TPO)/ Dispute Resolution Panel (DRP) erred on the facts and circumstances

THE ACIT,CENTRAL-1, INDORE vs. M/S PRAKASH OILS LTD., DHAR

In the result, the above captioned appeals filed by the Revenue as well as the

Bench: Shri C.M. Garg & Shri Bhagirath Mal Biyani

transfer pricing lies with the Transfer Pricing Office at Ahmedabad. The appellant, in order to save time and money appointed

THE ADDL. CIT RANGE -1, INDORE vs. M/S PRAKASH OILS LTD., DHAR

In the result, the above captioned appeals filed by the Revenue as well as the

Bench: Shri C.M. Garg & Shri Bhagirath Mal Biyani

transfer pricing lies with the Transfer Pricing Office at Ahmedabad. The appellant, in order to save time and money appointed

THE ACIT ,CENTRAL-1, INDORE vs. M/S PRAKASH OILS LTD., DHAR

In the result, the above captioned appeals filed by the Revenue as well as the

Bench: Shri C.M. Garg & Shri Bhagirath Mal Biyani

transfer pricing lies with the Transfer Pricing Office at Ahmedabad. The appellant, in order to save time and money appointed

THE ACIT, - 4(1), INDORE vs. M/S. YASH TECHNOLOGIES PVT. LTD., INDORE

In the result appeal of the revenue is dismissed

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Boradassessment Year 2014-15 Pan : Aaacy1868M

transfer pricing (TP) provisions, A.O. has to refer such transaction to the Transfer Pricing Officer. (iii) Section 10AA(9) (Corresponding

M/S ANDRITZ HYDRO PRIVATE LIMITED,BHOPAL vs. THE DCIT CIRCLE 1(1), BHOPAL

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

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S. Andritz Hydro Private Dcit Circe 1(1) Ltd. Bhopal Vs. D-17, Mpakvn Industrial Area, Mandideep Raisen (Appellant / Assessee) (Respondent/ Revenue) Pan: Aabcv 2466 R Assessee By Shri Rahul, Kaul Ar Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 13.06.2023 Date Of Pronouncement 28.08.2023

transferred or services provided in the international transaction [or the specified domestic transaction] ; (b) resale price method, by which,— (i) the price

THE ACIT, CENTRAL-1, INDORE vs. M/S. MANISH AGRO TECH PVT. LTD., INDORE

In the result grounds of revenue for A

Bench: Shri Chandra Mohan Garg & Shri Bhagirath Mal Biyani

transfer pricing lies with the Transfer Pricing Office at Ahmedabad. The appellant, in order to save time and money appointed

THE ACIT, CENTRAL-1, INDORE vs. M/S. MANISH AGRO TECH PVT. LTD., INDORE

In the result grounds of revenue for A

Bench: Shri Chandra Mohan Garg & Shri Bhagirath Mal Biyani

transfer pricing lies with the Transfer Pricing Office at Ahmedabad. The appellant, in order to save time and money appointed

M/S. SWASTIK COAL CORPORATION PVT. LTD.,INDORE vs. THE ACIT, 5(1), INDORE

In the result, the appeal filed by the assessee in ITA

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2014-15

Transfer Pricing Officer (TPO) to verify whether the specified domestic transactions were at arm’s length price or not. 3. In the facts

CUMMINS TECHNOLOGIES INDIA (P) LTD.,DEWAS vs. ACIT CIRCLE 1(1), UJJAIN

In the result, the appeal of the assesse is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanicommins Technologies India Acit, Circle -1(1) Private Limited Ujjain Vs. Industrial Area No.2, A.B. Road, M.P. (Appellant / Assessee) (Revenue) Pan: Aabct2018B Assessee By Shri Ketan Ved & Pinkesh Vakharia Ars Revenue By Ms. Simran Bhullar, Cit-Dr Date Of Hearing 29.11.2023 Date Of Pronouncement 30.11.2023

Transfer pricing adjustment of INR 4,84,19,012/- 1.1 On the facts and in circumstances of the case and in law, the learned

M/S ANDRITZ HYDRO PRIVATE LIMITED,BHOPAL vs. DEPUTY COMMISSIONER OF INCOME TAX-1 (1), BHOPAL

In the result, the appeals filed by the assessee are

Bench: Shri Kul Bharat & Shri Manish Borad

transfer pricing to the Transfer Pricing Officer (TPO). Thereafter, the A.O. passed a draft order on the basis of the recommendation