COMMISSIONER OF INCOME TAX vs. AMADEUS INDIA PVT LTD

Appeal is dismissed

reassessment or recomputation or fresh assessment, as the case may be, expires.] [(4) On receipt of the order under sub-section (3), the Assessing Officer shall proceed to compute the total income of the assessee under sub-section (4) of section 92C

RAMPGREEN SOLUTIONS PVT LTD vs. COMMISSIONER OF INCOME TAX

The appeal is allowed

Bench: The Tribunal, Impugning The Assessment Order Passed By The Assessing Officer (Hereafter ‘Ao’) Making The Transfer Pricing Adjustments (Hereafter ‘Tp Adjustments’) In Respect Of The Assessment Year (Hereafter ‘Ay’) 2008-09 As Finalised By The Transfer Pricing Officer 2015:Dhc:6421-Db

reassessment proceedings pending before an Assessing Officer as on the 1st day of October, 2009.” 19. It is also necessary to refer to Rule 10B of the Income Tax Rules, 1962 which provides for determination of ALP under Section 92C

DCIT, CENTRAL CIRCLE-20, DELHI vs. LOTUS HERBALS PVT. LTD, DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

reassessment proceedings, the Assessing Officer has issues summons u/s 133(6) of the Act to various parties, out of which four parties namely (i) M/s Krishna Attire & Hospitality Services (Krishna Attire) Rs.7,46,697/- (ii) M/s Shan Creations - Rs.25,69,331/- (iii) M/s Brand Vision - Rs.8,00,000/- and (iv) Symmetrix Prints Pvt. Ltd. (‘Symmetrix Prints)- Rs.1

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

reassessment proceedings, the Assessing Officer has issues summons u/s 133(6) of the Act to various parties, out of which four parties namely (i) M/s Krishna Attire & Hospitality Services (Krishna Attire) Rs.7,46,697/- (ii) M/s Shan Creations - Rs.25,69,331/- (iii) M/s Brand Vision - Rs.8,00,000/- and (iv) Symmetrix Prints Pvt. Ltd. (‘Symmetrix Prints)- Rs.1

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

reassessment proceedings, the Assessing Officer has issues summons u/s 133(6) of the Act to various parties, out of which four parties namely (i) M/s Krishna Attire & Hospitality Services (Krishna Attire) Rs.7,46,697/- (ii) M/s Shan Creations - Rs.25,69,331/- (iii) M/s Brand Vision - Rs.8,00,000/- and (iv) Symmetrix Prints Pvt. Ltd. (‘Symmetrix Prints)- Rs.1

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

reassessment proceedings, the Assessing Officer has issues summons u/s 133(6) of the Act to various parties, out of which four parties namely (i) M/s Krishna Attire & Hospitality Services (Krishna Attire) Rs.7,46,697/- (ii) M/s Shan Creations - Rs.25,69,331/- (iii) M/s Brand Vision - Rs.8,00,000/- and (iv) Symmetrix Prints Pvt. Ltd. (‘Symmetrix Prints)- Rs.1

DCIT, CENTRAL CIRCLE-20, NEW DELHI vs. LOTUS HERBALS P.LTD, DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

reassessment proceedings, the Assessing Officer has issues summons u/s 133(6) of the Act to various parties, out of which four parties namely (i) M/s Krishna Attire & Hospitality Services (Krishna Attire) Rs.7,46,697/- (ii) M/s Shan Creations - Rs.25,69,331/- (iii) M/s Brand Vision - Rs.8,00,000/- and (iv) Symmetrix Prints Pvt. Ltd. (‘Symmetrix Prints)- Rs.1

COSMIC INFORMATICS PVT. LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE - 2, NEW DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

reassessment proceedings, the Assessing Officer has issues summons u/s 133(6) of the Act to various parties, out of which four parties namely (i) M/s Krishna Attire & Hospitality Services (Krishna Attire) Rs.7,46,697/- (ii) M/s Shan Creations - Rs.25,69,331/- (iii) M/s Brand Vision - Rs.8,00,000/- and (iv) Symmetrix Prints Pvt. Ltd. (‘Symmetrix Prints)- Rs.1

COSMIC INFORMATICS PVT. LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE - 2, NEW DELHI

In the result, appeal of the Revenue in appeal No

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

reassessment proceedings, the Assessing Officer has issues summons u/s 133(6) of the Act to various parties, out of which four parties namely (i) M/s Krishna Attire & Hospitality Services (Krishna Attire) Rs.7,46,697/- (ii) M/s Shan Creations - Rs.25,69,331/- (iii) M/s Brand Vision - Rs.8,00,000/- and (iv) Symmetrix Prints Pvt. Ltd. (‘Symmetrix Prints)- Rs.1

COMMISSIONER OF INCOME-TAX-I

The appeal is dismissed

reassess the income in respect of any issue, which has 2013:DHC:1943-DB ITA No.578/12 Page 11 of 22 escaped assessment, and such issue comes to his notice subsequently in the course of the proceedings under this section, notwithstanding that the reasons for such issue have not been included in the reasons recorded under sub-section (2) of section

COMPAREX INDIA P.LTD,NEW DELHI vs. ITO, CIRCLE-4(2), NEW DELHI

In the result, the appeal filed by the assessee is partly allowed

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Accountant Member)

92C of the Act 4 read with Rule 10 of the Income Tax Rules. The TP order dated 27 July 2021 ought to be quashed. 6. On the facts and in law, the Ld. TPO exceeded its jurisdiction by applying the cost benefit analysis in determining the ALP of intra group charges and also erred in not following the binding