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

section 92CA(3) & 144C(5) of the Income-tax Act, 1961 for Assessment-Year [“AY”] 2007-08, the assessee has filed this appeal. Page 1 of 47 Computer Sciences Corporation India Private Limited, Chennai Assessment year 2007-08 2. This appeal was originally filed at Chennai Bench of ITAT on 10.10.2011 and registered as ITA No. 1654/CHNY/2011. The ITAT, Chennai

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

144C and 92CA of Income Tax Act,1961(hereinafter referred as of ”the Act”) of the Deputy Commissioner of Income tax- 1(1),Bhopal (hereinafter referred as “the AO”), for the assessment year 2010-11 order dated 13.02.2015 and for the A.Y. 2011-12 order dated 22.02.2016 passed in pursuance of the directions issued by Dispute Resolution Panel-IV, Mumbai

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

144C and 92CA of Income Tax Act,1961(hereinafter referred as of ”the Act”) of the Deputy Commissioner of Income tax- 1(1),Bhopal (hereinafter referred as “the AO”), for the assessment year 2010-11 order dated 13.02.2015 and for the A.Y. 2011-12 order dated 22.02.2016 passed in pursuance of the directions issued by Dispute Resolution Panel-IV, Mumbai

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

144C and 92CA of Income Tax Act,1961(hereinafter referred as of ”the Act”) of the Deputy Commissioner of Income tax- 1(1),Bhopal (hereinafter referred as “the AO”), for the assessment year 2010-11 order dated 13.02.2015 and for the A.Y. 2011-12 order dated 22.02.2016 passed in pursuance of the directions issued by Dispute Resolution Panel-IV, Mumbai

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

144C and 92CA of Income Tax Act,1961(hereinafter referred as of ”the Act”) of the Deputy Commissioner of Income tax- 1(1),Bhopal (hereinafter referred as “the AO”), for the assessment year 2010-11 order dated 13.02.2015 and for the A.Y. 2011-12 order dated 22.02.2016 passed in pursuance of the directions issued by Dispute Resolution Panel-IV, Mumbai

M/S. COMPUTER SCIENCE CORPORATION INDIA PVT. LTD.,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX-CIRCLE 2(1) , INDORE

In the result, all the three appeals are partly allowed for statistical purpose and the Stay Application is also disposed of

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

8) of the Act. 3. on the facts and circumstances of the case and in law the assessment order passed by the ld AO dated February 5, 2016 is based in law and is in violation of Section 144C(13) of the Act. Transfer Pricing

M/S. COMPUTER SCIENCE CORPORATION INDIA PVT. LTD.,CHENNAI vs. THE ACIT-CIRCLE 2(1), INDORE

In the result, all the three appeals are partly allowed for statistical purpose and the Stay Application is also disposed of

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

8) of the Act. 3. on the facts and circumstances of the case and in law the assessment order passed by the ld AO dated February 5, 2016 is based in law and is in violation of Section 144C(13) of the Act. Transfer Pricing

M/S. COMPUTER SCIENCES CORPORATION INDIA PRIVATE LIMITED,INDORE vs. THE ASST. COMMISSIONER OF INCOME TAX-2(1), INDORE

In the result, all the three appeals are partly allowed for statistical purpose and the Stay Application is also disposed of

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

8) of the Act. 3. on the facts and circumstances of the case and in law the assessment order passed by the ld AO dated February 5, 2016 is based in law and is in violation of Section 144C(13) of the Act. Transfer Pricing

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

144C of the Income-tax Act, 1961 ["hereinafter referred to as "the Act"] on the following Page 1 of 22 Cummins Technologies India P. ltd. Page 2 of 22 grounds which are independent of and without prejudice to each other. 1. General Ground: Transfer pricing adjustment of INR 4,84,19,012/- 1.1 On the facts and in circumstances

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

section 144C(13) of the Act in pursuant to the directions of DRP dated 25.01.2022 passed u/s 144C(5) of the Act for Assessment Year 2017-18. 2. The assesse is subsidiary of Andritz Hydro Private Limited GmbH Austria and engaged in the business of design, manufacture, servicing, erection and installation of hydro and thermal power generators. It is stated

M/S. BRIDGESTONE INDIA PVT. LTD.,PUNE vs. THE ACIT NFAC, DELHI

In the result, appeal of assessee is partly allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanibridgestone India Pvt. Ltd. Acit (Nfac) Plot No.A-43, Phase-Ii, Delhi Midc Chakan, Village Vs. Sawardari, Taluka Khed, Pune (Appellant / Assessee) (Respondent/ Revenue) Pan: Aabcb 2304 E Assessee By Shri Sukhsagar Syal, Ar Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 23.05.2023 Date Of Pronouncement 17.07.2023

transfer pricing documentation and economic analysis has passed an order dated 30.10.2018 under Section 92CA(3) of the Act determining the "Arm's Length Price" difference of Rs. 41,57,14,9471- in respect of royalty payment of its AE and Rs. 39,63,921/- in respect of international transactions relating to trading activities of the assessee. Thus, total upward

M/S. BRIDGESTONE INDIA PVT. LTD.,PUNA vs. THE ACIT-1(1), INDORE

The appeal of the assessee is allowed

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

transfer pricing documentation and economic analysis has passed an order dated 30.10.2018 Bridgestone India Pvt. Ltd. vs. ACIT Asst.Year –2015-16 - 3 – under Section 92CA(3) of the Act determining the “Arm’s Length Price” difference of Rs. 41,57,14,947/- in respect of royalty payment of its AE and Rs. 39,63,921/- in respect of international transactions

M/S LIMAGRAIN INDIA PVT. LTD. ,SECUNDERABAD, HYDRABAD vs. N.F.A.C, DELHI

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2017-18 M/S.Limagrain India National Faceless Private Limited, Assessment Centre, H.No. 1-8-201 To 203, Delhi Ashoka My Home बनाम/ Chambers, Flat No. 208, 209, 2Nd Vs. Floor, S.P.Road, Secunderabad, Hyderabad (Assessee / Appellant) (Revenue / Respondent) Pan: Aaccb6862A Assessee By Shri Pankaj Sancheti, Ca Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 21.12.2023 Date Of Pronouncement 19.01.2024

section 144C(13) & 144B of the Income-tax Act, 1961 [“the Act”] for Assessment-Year [“AY”] 2017-18, the assessee has filed this appeal. Page 1 of 20 M/s.Limagrain India Private Ltd., Indore. Vs. NFAC,Delhi Assessment year 2017-18 2. The registry has informed that that the present appeal is filed after a delay of 11 days and therefore

M/S. BHATIA GLOBAL TRADING LTD.,INDORE vs. THE DCIT 1(1), INDORE

In the result, appeal of assessee is partly allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanibhatia Global Trading Ltd. Dcit 1(1) Through Official Liquidator Indore Old Cia Building, 1St Floor Vs. Opp. G.P.O. Residency Area, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaacb6751 C Assessee By None Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 10.05.2023 Date Of Pronouncement 26 .07.2023

section 144C(13) in pursuant to the directions of DRP dated 26.12.2016 passed u/s 144C(5) of the Act for Assessment Year 2012-13. 2. The assesse has under gone the liquidation process before the NCLT vide order dated 22.10.2020 the liquidator was appointed by NCLT. Page 1 of 17 Bhatia Global Trading Ltd. Page 2 of 17 3. None

ANDRITZ HYDRO P LTD,BHOPAL vs. PR CIT-1, BHOPAL

Bench: Shri Manish Borad & Ms. Madhumita Royvirtual Hearing

144C r.w.s 92CA of the IT Act, 1961 dated 25.01.2018 passed by the DCIT-1(1), Bhopal for A.Y. 2014-15, The assessee company was engaged in the manufacturing of generators and its equipments besides providing installation and erection services. On perusal of the assessment order and case recordd, it is notices that the assessee company debited Rs.30