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

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

section 92B inserted by Finance Act, 2012 cannot extend scope of transaction retrospectively and accordingly, transfer pricing provision cannot apply to the said transaction. Without prejudice to the above 1.7 Without prejudice to above, the learned CIT (A) erred in summarily rejecting the comparability analysis undertaken by the Appellant to benchmark the transaction of provision of corporate guarantee

THE DCIT1(1), INDORE vs. M/S. AGRAWAL COAL CORPORATION P LTD., INDORE

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

section 92B inserted by Finance Act, 2012 cannot extend scope of transaction retrospectively and accordingly, transfer pricing provision cannot apply to the said transaction. Without prejudice to the above 1.7 Without prejudice to above, the learned CIT (A) erred in summarily rejecting the comparability analysis undertaken by the Appellant to benchmark the transaction of provision of corporate guarantee

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

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

section 92B inserted by Finance Act, 2012 cannot extend scope of transaction retrospectively and accordingly, transfer pricing provision cannot apply to the said transaction. Without prejudice to the above 1.7 Without prejudice to above, the learned CIT (A) erred in summarily rejecting the comparability analysis undertaken by the Appellant to benchmark the transaction of provision of corporate guarantee

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

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

section 92B inserted by Finance Act, 2012 cannot extend scope of transaction retrospectively and accordingly, transfer pricing provision cannot apply to the said transaction. Without prejudice to the above 1.7 Without prejudice to above, the learned CIT (A) erred in summarily rejecting the comparability analysis undertaken by the Appellant to benchmark the transaction of provision of corporate guarantee

MAHENDRA SINGH CHAWLA,INDORE vs. DCIT CIRCLE-1(1), INDORE

In the result, the appeal of the assessee is dismissed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanimahendra Singh Chawla Dcit Circle -1(1) 4/35 Gram Pigdamber A.B. Indore Road Near Rao Vs. Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aazpc0120C Assessee By None Shri Ashish Porwal, Sr. Dr Revenue By Date Of Hearing 02.09.2024 Date Of Pronouncement 04 .09.2024

22-08-1997. An Irrevocable Power of Attorney was also signed thereby passing all rights to dispose of the developed property and to utilize advance and sale consideration. It was decided by the Tribunal that was a transfer of property under Section 53A of the Transfer of Property Act, 1882, which fell within scope of Section

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 provisions could apply if the aggregate of such transactions entered into by the assessee in the previous year exceeds a sum of Rs.5 crores. But in the instant case the specified domestic pricing figure is Rs.3,46,13,572/- which is less than Rs.5 crores hence the provision of Section 92BA of the Act does not apply

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 documentation requirements. 12. The ld. AO and Hon'ble DRP have erred, in law and in facts, by applying the turnover ≤ Rs. 1 crore as a comparability criterion. 13. The ld. AO and Hon'ble DRP have erred, in law and in facts, by rejecting certain comparable companies identified by the assessee as having economic performance contrary

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

22 of 84 M/s. Andritz Hydro Pvt. Ltd v DCIT/ T.P.A. No.157/Ind/2015 &316/Ind/2016/ A.Y.:10-11&11-12 DCIT vs. Andritz Hydro Pvt. Ltd T.P. A. No. 265/Ind/2015 & 349/Ind/2016/A.Y.:10-11&11-12 transaction related to ‘’payment for technical service” by determining the arm`s length price of such payments as NIL 3.1. Briefly, stated the facts of the case

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

22 of 84 M/s. Andritz Hydro Pvt. Ltd v DCIT/ T.P.A. No.157/Ind/2015 &316/Ind/2016/ A.Y.:10-11&11-12 DCIT vs. Andritz Hydro Pvt. Ltd T.P. A. No. 265/Ind/2015 & 349/Ind/2016/A.Y.:10-11&11-12 transaction related to ‘’payment for technical service” by determining the arm`s length price of such payments as NIL 3.1. Briefly, stated the facts of the case

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

22 of 84 M/s. Andritz Hydro Pvt. Ltd v DCIT/ T.P.A. No.157/Ind/2015 &316/Ind/2016/ A.Y.:10-11&11-12 DCIT vs. Andritz Hydro Pvt. Ltd T.P. A. No. 265/Ind/2015 & 349/Ind/2016/A.Y.:10-11&11-12 transaction related to ‘’payment for technical service” by determining the arm`s length price of such payments as NIL 3.1. Briefly, stated the facts of the case

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

22 of 84 M/s. Andritz Hydro Pvt. Ltd v DCIT/ T.P.A. No.157/Ind/2015 &316/Ind/2016/ A.Y.:10-11&11-12 DCIT vs. Andritz Hydro Pvt. Ltd T.P. A. No. 265/Ind/2015 & 349/Ind/2016/A.Y.:10-11&11-12 transaction related to ‘’payment for technical service” by determining the arm`s length price of such payments as NIL 3.1. Briefly, stated the facts of the case

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 officer, Ahmedabad (TPO) in the order passed u/s 92CA(3). 4.2. The appellant company has entered into transaction of sale and purchase of goods from its sister concern mainly from M/s. Manish Agrotech Limited Ltd. and it has purchased goods worth Rs. 41,67,84,935 - and sold goods worth Rs. 22,20,74,867/- to M/s Manish

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 officer, Ahmedabad (TPO) in the order passed u/s 92CA(3). 4.2. The appellant company has entered into transaction of sale and purchase of goods from its sister concern mainly from M/s. Manish Agrotech Limited Ltd. and it has purchased goods worth Rs. 41,67,84,935 - and sold goods worth Rs. 22,20,74,867/- to M/s Manish

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 officer, Ahmedabad (TPO) in the order passed u/s 92CA(3). 4.2. The appellant company has entered into transaction of sale and purchase of goods from its sister concern mainly from M/s. Manish Agrotech Limited Ltd. and it has purchased goods worth Rs. 41,67,84,935 - and sold goods worth Rs. 22,20,74,867/- to M/s Manish

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 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 or services provided in a comparable uncontrolled

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

section 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

M/S SHREE JAIRAM EDUCATION SOCIETY,BHOPAL vs. ACIT CENTRAL-II, BHOPAL

In the result, appeal of the assessee in ITANo

Bench: Hon’Ble Rajpal Yadav & Shri Manish Boradvirtual Hearing

22,811 was granted. Department is not in appeal against this relief granted by the Ld. CIT(A). [PB 117] 12. Ld. Pr. CIT(Central), Bhopal erred in not considering the submissions made by the assessee and proceeded to allege that the funds are siphoned and the fees are not fully reflected. Considering the above facts, circumstances of the case

M/S SHREE JAIRAM EDUCATION SOCIETY,BHOPAL vs. PR. CIT (CENTRAL), BHOPAL

In the result, appeal of the assessee in ITANo

Bench: Hon’Ble Rajpal Yadav & Shri Manish Boradvirtual Hearing

22,811 was granted. Department is not in appeal against this relief granted by the Ld. CIT(A). [PB 117] 12. Ld. Pr. CIT(Central), Bhopal erred in not considering the submissions made by the assessee and proceeded to allege that the funds are siphoned and the fees are not fully reflected. Considering the above facts, circumstances of the case

ACIT-2(1), UJJAIN, UJJAIN vs. M/S RUCHI J OIL PVT. LTD,, MUMBAI

In the result, Revenue’s appeal ITANo

Bench: Shri Mahavir Prasad & Shri Manish Boradvirtual Hearing Assessment Year: 2014-15

Pricing Officer (TPO) on page no.2 of its order u/s 92CA(3) of the Act had mentioned that the details of International Transaction in term of section 92B and Specified Domestic Transaction in terms of section 92BA of the Act between the assessee and its Associate Enterprise are given in form 3CEB. Further, the AO has also mentioned in para