TATA CUMMINS PRIVATE LIMITED,PUNE vs. THE DCIT CIRCLE-1-JAMSHEDPUR AND THE ASSESSMENT UNIT, INCOME-TAX DEPARTMENT, NFAC, DELHI, JAMSHEDPUR

In the result, appeal of the assessee is partly allowed for statistical purposes

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaytata Cummins Private Limited, D.C.I.T., Cummins India Office, Tower-A, 7Th Circle-1, Vs. Floor, Survey No. 21, Balewadi, Pune, Jamshedpur. Maharashtra. Pan No. Aaact 6353 L Appellant/ Assessee Respondent/ Revenue

Transfer Pricing Officer was of the view that the license granted by Cummins to the assessee included any R&D development done by Tata Cummins Vs DCIT the assessee on the engine technology and the patents which was owned by Cummins and therefore, the R&D developments that has been done by the assessee was owned by Cummins Incorporated

ASHOK KUMAR PANDEY,DHANBAD vs. PR. CIT, DHANBAD

In the result, this appeal of assessee is allowed

Shri George Mathan & Shri Ratnesh Nandan Sahay