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

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

TP regulations are restricted to determination of the arm’s length price of the international transaction. The relevant extract from the said ruling is reproduced below for reference: “8. We find that the basic reason of the Transfer Pricing Officer’s determination of ALP of the services received under cost contribution arrangement as ‘NIL’ is his perception that the Assessee

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

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

TP regulations are restricted to determination of the arm’s length price of the international transaction. The relevant extract from the said ruling is reproduced below for reference: “8. We find that the basic reason of the Transfer Pricing Officer’s determination of ALP of the services received under cost contribution arrangement as ‘NIL’ is his perception that the Assessee

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

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

TP regulations are restricted to determination of the arm’s length price of the international transaction. The relevant extract from the said ruling is reproduced below for reference: “8. We find that the basic reason of the Transfer Pricing Officer’s determination of ALP of the services received under cost contribution arrangement as ‘NIL’ is his perception that the Assessee

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

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

TP regulations are restricted to determination of the arm’s length price of the international transaction. The relevant extract from the said ruling is reproduced below for reference: “8. We find that the basic reason of the Transfer Pricing Officer’s determination of ALP of the services received under cost contribution arrangement as ‘NIL’ is his perception that the Assessee

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 adjustment was made in which the arm`s length price determined was Nil for technical services received from AE’s of which payments made were already covered under technical royalty agreement. It was explained that in respect of Mandideep unit , the entity had entered in to an agreement with the AE’s which was altogether different from

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 adjustment was made in which the arm`s length price determined was Nil for technical services received from AE’s of which payments made were already covered under technical royalty agreement. It was explained that in respect of Mandideep unit , the entity had entered in to an agreement with the AE’s which was altogether different from

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 adjustment was made in which the arm`s length price determined was Nil for technical services received from AE’s of which payments made were already covered under technical royalty agreement. It was explained that in respect of Mandideep unit , the entity had entered in to an agreement with the AE’s which was altogether different from

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 adjustment was made in which the arm`s length price determined was Nil for technical services received from AE’s of which payments made were already covered under technical royalty agreement. It was explained that in respect of Mandideep unit , the entity had entered in to an agreement with the AE’s which was altogether different from

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 proceedings of subsequent year i.e. AY 2016-17 has also been since completed by the TP0-2, Ahemdabad, where-in the CUP method adopted by the appellant company has been accepted as the most appropriate method. Copy of the order passed by the TPO for AY’s 2013- 14, 2014-15 and 2016-17 is enclosed at page

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 proceedings of subsequent year i.e. AY 2016-17 has also been since completed by the TP0-2, Ahemdabad, where-in the CUP method adopted by the appellant company has been accepted as the most appropriate method. Copy of the order passed by the TPO for AY’s 2013- 14, 2014-15 and 2016-17 is enclosed at page

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 proceedings of subsequent year i.e. AY 2016-17 has also been since completed by the TP0-2, Ahemdabad, where-in the CUP method adopted by the appellant company has been accepted as the most appropriate method. Copy of the order passed by the TPO for AY’s 2013- 14, 2014-15 and 2016-17 is enclosed at page

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

Transfer Pricing Study Report the assesse has benchmarked its International transactions by applying TNMM as the most appropriate method with PLI as OP/OC and compared with the internal unrelated/uncontrolled transactions of domestic sales having profit margin @ 10.62% in comparison to the average gross margin of aggregated all international transactions @ 17.80%. Thus, the assesse has claimed that its international transactions

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 is concerned with the determination of Arm’s Length Price of the specified domestic transactions carried out by the assessee. The learned CIT-DR submitted that the doctrine of res judicata does not apply for the tax proceedings. Therefore the Ld. CIT(A) was not correct in deleting the impugned upward adjustment made by the TPO in respect

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 is concerned with the determination of Arm’s Length Price of the specified domestic transactions carried out by the assessee. The learned CIT-DR submitted that the doctrine of res judicata does not apply for the tax proceedings. Therefore the Ld. CIT(A) was not correct in deleting the impugned upward adjustment made by the TPO in respect

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

method nor has been able to demonstrate the same while carrying out the benchmarking analysis. 5.3 On the facts and in circumstances of the case and in law, the learned AO / TPO pursuant to the directions of Hon'ble DRP, has erred in making transfer pricing addition of INR 1,58,78,915/- in spite of the fact that

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

transfer pricing regulations 5. The TPO rejected the TP Study analysis of the assesse and carried out his own search for selecting comparable for determination of arm’s length price. The TPO selected three comparable companies for determination of arm’s length price against which the assessee has raised objection before the DRP which are reproduced

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 adjustments. The A.O. on the basis of the recommendation 3 [ITA 685 & 687/Ind/2017] [Andritz Hydro Private Limited, Mandideep, Bhopal] of the TPO made adjustments in respect of transactions related to receipt of contract revenue from projects and adjustment of difference on account of arm’s length price for transactions related to payment of technical services to the Associated

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

Transfer Pricing Officer (TPO) as the Assessing Officer noticed that the assessee has entered into international transactions with it’s associated concerns. The TPO vide order dated 01.01.2015 under Section 92CA(3) made an upward adjustment of Rs.212,56,79,027/- on account of software services. After receipt of the order of the ITA Nos.179/Ind/2016, 292/Ind/2017, 319/Ind/2018 & SA No.46/Ind/2021 A.Ys

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

Transfer Pricing Officer (TPO) as the Assessing Officer noticed that the assessee has entered into international transactions with it’s associated concerns. The TPO vide order dated 01.01.2015 under Section 92CA(3) made an upward adjustment of Rs.212,56,79,027/- on account of software services. After receipt of the order of the ITA Nos.179/Ind/2016, 292/Ind/2017, 319/Ind/2018 & SA No.46/Ind/2021 A.Ys