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Documents citing Acit, New Delhi vs M/S Gates India (P) Ltd., New Delhi on 31 July, 2017

Acit, Circle- 27(2), New Delhi vs Yutaka Autoparts India Pvt. Ltd., Delhi on 16 October, 2024

47. When the taxpayer has brought on record the complete analysis of cash profits earned by the taxpayer to be compared with complete analysis of cash profit earned by the comparable companies extracted in the preceding paras, we are of the considered view that the issue is required to be decided afresh by the TPO in the light of the decision rendered by the coordinate Bench of the Tribunal in ACIT vs. Gates India (P) Ltd. and Schefenacker Motherson Ltd. vs. ITO (supra). So, ground no.6 is allowed for statistical purposes.
Income Tax Appellate Tribunal - Delhi Cites 12 - Cited by 0 - Full Document

Yutaka Autoparts India Pvt. Ltd., Delhi vs Dcit, Circle- 27(1), New Delhi on 16 October, 2024

47. When the taxpayer has brought on record the complete analysis of cash profits earned by the taxpayer to be compared with complete analysis of cash profit earned by the comparable companies extracted in the preceding paras, we are of the considered view that the issue is required to be decided afresh by the TPO in the light of the decision rendered by the coordinate Bench of the Tribunal in ACIT vs. Gates India (P) Ltd. and Schefenacker Motherson Ltd. vs. ITO (supra). So, ground no.6 is allowed for statistical purposes.
Income Tax Appellate Tribunal - Delhi Cites 12 - Cited by 0 - Full Document

Yutaka Autoparts India Pvt. Ltd., Delhi vs Ito, New Delhi on 16 October, 2024

47. When the taxpayer has brought on record the complete analysis of cash profits earned by the taxpayer to be compared with complete analysis of cash profit earned by the comparable companies extracted in the preceding paras, we are of the considered view that the issue is required to be decided afresh by the TPO in the light of the decision rendered by the coordinate Bench of the Tribunal in ACIT vs. Gates India (P) Ltd. and Schefenacker Motherson Ltd. vs. ITO (supra). So, ground no.6 is allowed for statistical purposes.
Income Tax Appellate Tribunal - Delhi Cites 12 - Cited by 0 - Full Document

Yutaka Autoparts India Pvt. Ltd., Delhi vs Ito, New Delhi on 4 July, 2018

47. When the taxpayer has brought on record the complete analysis of cash profits earned by the taxpayer to be compared with complete analysis of cash profit earned by the comparable companies extracted in the preceding paras, we are of the 26 ITA No.1807/Del./2015 considered view that the issue is required to be decided afresh by the TPO in the light of the decision rendered by the coordinate Bench of the Tribunal in ACIT vs. Gates India (P) Ltd. and Schefenacker Motherson Ltd. vs. ITO (supra). So, ground no.6 is allowed for statistical purposes.
Income Tax Appellate Tribunal - Delhi Cites 6 - Cited by 0 - Full Document

Subex Limited, Bangalore vs Deputy Commissioner Of Income Tax, ... on 27 February, 2023

Acquisition of subsidiary - Discoverture Solutions LLC 42. The DRP while dealing with the aforesaid objections has merely taken the view that the presence of IPR revenue was insignificant and so also expenses of brand value, R&D & intangibles. More importantly, the DRP did not dispute the presence of 46% of revenue from onsite model, but went on to hold that the presence of revenue is not sufficient to exclude a company, when it is otherwise functionally comparable. On this aspect, we have already referred to the decision of the ITAT Bangalore Bench in the case of Trilogy e-business Software India P. Ltd. (supra) and in the light of this decision and the admitted factual position regarding presence of onsite revenue over and above the threshold limit of 25% of total revenue, we are of the view that this company should be excluded from the list of comparable companies. We hold and direct accordingly."
Income Tax Appellate Tribunal - Bangalore Cites 48 - Cited by 0 - Full Document

M/S Subex Limited , Bangalore vs Deputy Commissioner Of Income Tax ... on 5 October, 2018

4. He also placed reliance on another Tribunal order rendered in the case of ACIT Vs. Gates India (P) Ltd. in ITA No. 75/Del/2011 dated 31.07.2017. He submitted a copy of this Tribunal order also and drawn our attention to para no. 7 of this Tribunal order and pointed out that in that case, the TPO considered the TNMM as well as CUP method as most appropriate method in respect of two transactions of import of goods and sale of finished products to the A.E. because in that case, the assessee was importing raw material from its A.E. and also making exports of the finished goods to the A.E. He pointed out that under these facts, it was held by Tribunal in that case that it is not proper to apply separate methods for determining the ALP for each of the transactions particularly when the international transactions are closely linked and inter- depending having direct bearing on the price of each other. The ld. DR of revenue supported the orders of authorities below and he also submitted that the matter may be restored back to the file of TPO for fresh decision in the light of these Tribunal orders.
Income Tax Appellate Tribunal - Bangalore Cites 9 - Cited by 0 - Full Document
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