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GLBAL E-BUSINESS OPERATIONS PRIVATE LIMITED VS DEPUTY COMMISSIONER OF INCOME TAX
BANGALORE TRIBUNAL, Sep 27, 2022

Once a company falls into the category of high-end KPO, it cannot be functionally comparable with a BPO service provider like that of assessee.

Subject : Selection of comparables of IT enabled services
Legislation Referred To : Section 37, 40(a)(i), 192, 195, 143(3)
In Favour Of : Assessee

DEPUTY COMMISSIONER OF INCOME TAX VS OSRAM INDIA PVT. LTD.
DELHI TRIBUNAL, Sep 22, 2022

1. This appeal filed by the Revenue is directed against the order dated 15.01.2018 passed by the Commissioner of Income Tax (Appeals)-I, Gurgaon relating to Assessment Year...

Subject : Transfer pricing adjustment
Legislation Referred To : Section 40(a)(ia), 194C, 143(2), 142(1), 144C
In Favour Of : Assessee

SUPER BRANDS LTD. (UK) VS ADDITIONAL COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)
DELHI TRIBUNAL, Sep 20, 2022

There is no variation in the income or loss returned, which is prejudicial to the interests of the assessee so the second condition prescribed in sec.144C(1) was not...

Subject : Appeals
Legislation Referred To : Section 144C, 92B, 143(3)
In Favour Of : Assessee (partly)

HP INDIA SALES PRIVATE LIMITED VS JOINT COMMISSIONER OF INCOME TAX
BANGALORE TRIBUNAL, Aug 18, 2022

1. This appeal at the instance of the assessee is directed against final assessment order dated 03.01.2017 passed u/s 143(3) r.w.s. 144C(13) of the I.T.Act. The relevant...

Legislation Referred To : Section 143(3), 144C, 92C(1), 271(1)(c)
In Favour Of : Assessee (partly)

AUROBINDO PHARMA LTD. VS DEPUTY COMMISSIONER OF INCOME TAX
HYDERABAD TRIBUNAL, Aug 18, 2022

Where the TPO did not resort to any transfer pricing exercise as per any of methods prescribed in section 92C(1) and determine the ALP of the transaction at nil, transfer...

Subject : Non residents
Legislation Referred To : Section 92CA, 143(3), 153A
In Favour Of : Assessee

TRIMBLE SOLUTIONS INDIA PVT. LTD. VS INCOME TAX OFFICER
BOMBAY TRIBUNAL, Aug 17, 2022

Once margin of profit in distribution segment has been accepted after consideration of management fees, then there is no question of making any separate adjustment insofar...

Subject : Transfer pricing adjustment
Legislation Referred To : Section 40(a)(i), 143(3), 144C(13), 253
In Favour Of : Assessee (partly)

XCHANGING SOLUTIONS LTD. VS DEPUTY COMMISSIONER OF INCOME TAX
BANGALORE TRIBUNAL, Aug 16, 2022

1. Present appeal is filed by assessee against final assessment order dated 23/10/2019 passed by the Ld.DCIT, Circle - 7(1)(2), Bangalore on following grounds of...

Legislation Referred To : Section 92B(1), 133(6), 143(3), 144C(13)
In Favour Of : Matter remanded

L.G. ELECTRONICS INDIA PVT. LTD. VS ASSISTANT COMMISSIONER OF INCOME TAX
DELHI TRIBUNAL, Aug 16, 2022

Advertisements are aimed at promoting the sales of the product sold under trademark 'LG' manufactured by the assessee and not towards promoting the brand name of the AE in...

Subject : Transfer pricing adjustments
Legislation Referred To : Section 92C(3), 37, 80JJAA, 144C
In Favour Of : Assessee

TUPPERWARE INDIA PVT. LTD. VS ADDITIONAL COMMISSIONER OF INCOME TAX
DELHI TRIBUNAL, Aug 01, 2022

An 'assumed' price cannot form the reason for making an ALP adjustment, since a quantitative adjustment is not permissible for the purposes of a TP adjustment under Chapter...

Subject : Associate enterprises and international transactions
Legislation Referred To : Section40(a)(i), 143(3), 144(C), 195
In Favour Of : Matter remanded

CORTEVA AGRISCIENCE INDIA PVT. LTD. VS DEPUTY COMMISSIONER OF INCOME TAX
DELHI TRIBUNAL, Jul 28, 2022

There is no discussion by the DRP in respect of additional evidences and the objections raised by the assessee before the DRP hence issue is restored.

Subject : Transfer pricing adjustments
Legislation Referred To : Section
In Favour Of : Matter remanded