(Now known as Sony India Limited)

Transfer Pricing Officer during the course of the proceeding before him, the provisions of this Chapter shall apply as if such transaction is an international transaction referred to him under sub-section (1). ###(2C) Nothing contained in sub-section (2B) shall empower the Assessing Officer either to assess or reassess under section 147

RANBAXY LABORATORIES LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, we direct the AO to reduce the book profit u/s 115JB of the Act by the amount of reversal of the provision of Rs

Bench: Sh. I. C.Sudhir Judicialmember & Sh. Prashant Maharishia.Y.: - 2008-09 Ranbaxy Laboratories Ltd. Vs Acit 12Th Floor, Devika Tower, Range -15 6, Nehru Place New Delhi New Delhi Pan No. Aaacr0127N (Appellant) (Respondent)

Section (2) to Section 14A of the Act and sub Rule (1) to Rule 8D of the Rules. 14. The view and legal ratio expressed above is not being elucidated for the first time. The Delhi High Court in Maxopp Investment Ltd. v. CIT [2012] 347 ITR 272/203 Taxman 364/15 taxmann.com 390 has observed:- 'Scope of sub-sections

AMADEUS INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, ITA NO. 7691/Del/2017 stands allowed

Bench: Shri N.S. Saini & Shri Sudhanshu Srivastava

147, page 111 to AE is not justified The burden is on the assessed to select and justify the method adopted and the arm’s length price declared under sub-section (3) to section 92C, the Assessing Officer can proceed to determine the arm’s length price in accordance with Section 92C(1) and (2) on the basis of material

AMADEUS INDIA PVT. LTD.,NEW DELHI vs. ACIT, CIRCLE- 2(2), NEW DELHI

In the result, ITA NO. 7691/Del/2017 stands allowed

Bench: Shri N.S. Saini & Shri Sudhanshu Srivastava

147, page 111 to AE is not justified The burden is on the assessed to select and justify the method adopted and the arm’s length price declared under sub-section (3) to section 92C, the Assessing Officer can proceed to determine the arm’s length price in accordance with Section 92C(1) and (2) on the basis of material

AMADEUS INDIA PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, ITA NO. 7691/Del/2017 stands allowed

Bench: Shri N.S. Saini & Shri Sudhanshu Srivastava

147, page 111 to AE is not justified The burden is on the assessed to select and justify the method adopted and the arm’s length price declared under sub-section (3) to section 92C, the Assessing Officer can proceed to determine the arm’s length price in accordance with Section 92C(1) and (2) on the basis of material

LG ELECTRONICS INC., KOREA (LGEK),NOIDA vs. DCIT, CIRCLE- 2(2)(1), INTERNATIONAL TAXATION , NEW DELHI

In the result all the 9 appeals filed by the assessee are allowed with above direction for statistical purposes

Bench: Smt Diva Singh & Shri Prashant Maharishi

Section 147 of the Act even though all the transaction between LGIL and Assessee were held to be at arm’s length by the Ld. Transfer Pricing

M/S. LG ELECTRONICS INC., KOREA (LGEK),NOIDA vs. DCIT (INTERNATIONAL TAXATION), NOIDA

In the result all the 9 appeals filed by the assessee are allowed with above direction for statistical purposes

Bench: Smt Diva Singh & Shri Prashant Maharishi

Section 147 of the Act even though all the transaction between LGIL and Assessee were held to be at arm’s length by the Ld. Transfer Pricing

LG ELECTRONICS INC., KOREA (LGEK),NOIDA vs. DCIT, CIRCLE- NOIDA, INTERNATIONAL TAXATION, NOIDA

In the result all the 9 appeals filed by the assessee are allowed with above direction for statistical purposes

Bench: Smt Diva Singh & Shri Prashant Maharishi

Section 147 of the Act even though all the transaction between LGIL and Assessee were held to be at arm’s length by the Ld. Transfer Pricing