DEPUTY COMMISSIONER OF INCOME TAX, GUNTUR vs. CCL PRODUCTS (INDIA) LIMITED, GUNTUR

In the result, appeal filed by the Revenue is dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A. No.97/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2011-12) Deputy Commissioner Of Income V. Ccl Products (India) Limited, Tax, Guntur-522330, Guntur-522004. Andhra Pradesh. Pan: Aaacc9552G (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

2) of section 92C, the difference to the extent of 3% is permissible. We further find that the assessee by submitting all the details explained before the TPO that the assessee has charged for AE as well as non-AE similar prices for the supply of instant Page No. 15 ITA NO. 97, 98 & 152/Viz/2025 DCIT VS. CCL PRODUCTS INDIA

TEEJAY INDIA PRIVATE LIMITED,VISAKHAPATNAM vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-5(1), VISAKHAPATNAM

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

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.340/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2020-21) & S.A. No. 15/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2020-21) Teejay India Private Limited, Vs. Deputy Commissioner Of Plot No. 15, Brandix, Apsez, Income Tax, Pudimadaka Road, Atchutapuram Circle-5(1), Mandal, Visakhapatnam-530011. Visakhapatnam. Pan: Aaaco9452H (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

2. On the facts and in the circumstances of the case, the Ld. DRP/AO/TPO erred in: 2.1. Making an adjustment of INR 24,84,58,065/- to the income of the appellant by disallowing the payment to the AE in relation to the technical assistance received during the year; 2.2. In doing so, the Ld. DRP/AO/TPO erred in rejecting

TEEJAY INDIA PRIVATE LIMITED,VISAKHAPATNAM vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-5(1), VISAKHAPATNAM

Bench: Shri Ravish Sood, Hon’Ble & Shri Omkareshwar Chidara, Hon’Ble

2 I.T.A.No.533/VIZ/2024 Teejay India Private Limited assessment for verification of certain issues, viz. (i) large specified domestic transactions; and (ii) international transactions in respect of intangible property. 3. During the course of the assessment proceedings, the AO, made a reference to the DC/ACIT – TP-3, Hyderabad (for short “TPO”) for determining the Arm’s Length Price (for short