COMMISSIONER OF INCOME TAX vs. AMADEUS INDIA PVT LTD

Appeal is dismissed

section 92C to the Transfer Pricing Officer. (2) Where a reference is made under sub-section (1), the Transfer Pricing

DCIT, CIRCLE- 16(2), NEW DELHI vs. MENETA AUTOMOTIVE COMPONENTS PVT. LTD., NEW DELHI

In the result, the appeal of the Revenue is dismissed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

Transfer Pricing Officer (TPO). Sub-section (3) of Section 92CA provides that the TPO, after taking into account the material available with him shall, by an order in writing, determine the ALP in accordance with sub section (3) of Section 92C

PCIT-1, NEW DELHI vs. BEAM GLOBAL SPIRITS & WINE (INDIA) PVT. LTD.

Bench: HON'BLE MR. JUSTICE HARISH VAIDYANATHAN SHANKAR,HON'BLE MR. JUSTICE YASHWANT VARMA

92C. The fourth step would be to compare the price of the transaction that is shown to exist with the arm's length price and make the transfer pricing adjustment by substituting the arm's length price for the contract price. 63. A reading of the heading of section

PCIT-1, NEW DELHI vs. BEAM GLOBAL SPIRITS & WINE (INDIA)PVT.LTD.

Bench: HON'BLE MR. JUSTICE HARISH VAIDYANATHAN SHANKAR,HON'BLE MR. JUSTICE YASHWANT VARMA

92C. The fourth step would be to compare the price of the transaction that is shown to exist with the arm's length price and make the transfer pricing adjustment by substituting the arm's length price for the contract price. 63. A reading of the heading of section

COMMISSIONER OF INCOME TAX vs. MENTOR GRAPHICS (NOIDA) PVT.LTD

The appeal is allowed

Transfer Pricing Officer under section 92CA of the said Act for determination of the arm’s length price. At this juncture it would be relevant to note the provisions of section 92C

DCIT, NEW DELHI vs. M/S. NEW DELHI TELEVISION LTD., NEW DELHI

Bench: Shri H. S. Sidhu & Shri Prashant Maharishinew Delhi Television Ltd, Vs. Acit, 207, Okhla Industrial Estate, Phase- Circle-13(1), Iii, New Delhi New Delhi Pan: Aaacn0865D (Appellant) (Respondent) Acit, Vs. New Delhi Television Ltd, Circle-13(1), 207, Okhla Industrial Estate, New Delhi Phase-Iii, New Delhi Pan: Aaacn0865D (Appellant) (Respondent)

price has already been given by the TPO and, therefore, opportunity by the Assessing Officer, for final determination of income under sub-section (4) of section 92C, read with sub-section (4) of section 92CA is to be given by the Assessing Officer. (iv) Maintenance of database: It is to be ensured by the DIT (Transfer

M/S. NEW DELHI TELEVISION LTD.,NEW DELHI vs. ACIT, NEW DELHI

Bench: Shri H. S. Sidhu & Shri Prashant Maharishinew Delhi Television Ltd, Vs. Acit, 207, Okhla Industrial Estate, Phase- Circle-13(1), Iii, New Delhi New Delhi Pan: Aaacn0865D (Appellant) (Respondent) Acit, Vs. New Delhi Television Ltd, Circle-13(1), 207, Okhla Industrial Estate, New Delhi Phase-Iii, New Delhi Pan: Aaacn0865D (Appellant) (Respondent)

price has already been given by the TPO and, therefore, opportunity by the Assessing Officer, for final determination of income under sub-section (4) of section 92C, read with sub-section (4) of section 92CA is to be given by the Assessing Officer. (iv) Maintenance of database: It is to be ensured by the DIT (Transfer

(Now known as Sony India Limited)

section 92C to the Transfer Pricing Officer. (2) Where a reference is made under sub-section (1), the Transfer Pricing

LI & FUNG INDIA PVT LTD vs. COMMISSIONER OF INCOME TAX

The appeal is allowed and the order dated 25/11/11 of the ITAT Tribunal, Delhi Branch

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

92C having regard to the arm‟s length price determined under sub-section (3) by the Transfer Pricing Officer.” 30. It would

DCIT, NEW DELHI vs. M/S. BBC WORLD INDIA (P) LTD., NEW DELHI

In the result appeal of the assessee and the learned assessing officer are allowed for statistical purposes

Bench: Shri Kuldip Singh & Shri Prashant Maharishi

Transfer Pricing Officer’ means a Joint Commissioner or Deputy Commissioner or Assistant Commissioner , authorised by the board to perform all or any of the functions of an ‘Assessing Officer’ specified in section 92C