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M/S Bergen Engines India Pvt. Ltd.,, New ... vs Acit, New Delhi on 5 February, 2021 cites

Antitrust - Section 26(6) Disclaimer: ... vs M/S Aci Worldwide Solutions Private ... on 13 January, 2015

In support of above prayer of quashed the order, the Ld. AR relied upon the judgment of Hon'ble Mumbai High Court in the case of CIT v. M/s. Maersk Global Service Centre (I) Pvt. Ltd. [ITA No. 692 & 693 of 2012] wherein the Ld. DR alleged that Transfer pricing order has in a short and cryptic order as he did not identify the parties / instances as comparable. The Ld. AR also stated that Transfer Pricing Officer blindly and boldly refused to carry out the exercise and thereafter passed an order in terms of section 92CA sub-section (3) thus the matter ought to go back to the Transfer Pricing Officer. However, the Hon'ble High Court dismissed this ground and does not allow the 2nd chance of inning to TPO and upheld the ITAT order. The Mumbai ITAT in the case of Supermax Personal Care Private Limited v. ACIT [I.T.A. No. 1840/Mum/2017] follows the above view of Hon'ble Mumbai High Court in the case of CIT v. M/s. Maersk Global Service Centre (I) Pvt. Ltd. [ITA No. 692 & 693 of 2012].
Competition Commission of India Cites 20 - Cited by 153 - Full Document

Ameriprise India Pvt. Ltd., Gurgaon vs Assessee on 19 January, 2016

• Colt Technology Services India Pvt. Ltd v Dy CIT • Sum Total Systems (India) Pvt. Ltd v ITO • Adobe Systems India Pvt. Ltd • Genisys Intergrating Systems India Limited • Ameriprise India Pvt. Limited v DCIT • First Advantage Offshore Services Pvt. Ltd. • Agilent Technologies Delhi Considering the above facts and the case laws, the Ld. AR submitted that carrying out the fresh search process without giving the assessee the complete 16 ITA No. 5543/Del/2016 search process is bad in law and not warranted under chapter X of the Act hence, prayed to be rejected.
Income Tax Appellate Tribunal - Delhi Cites 11 - Cited by 12 - Full Document

Poonam Promoters & Developers (P) ... vs Department Of Income Tax on 16 February, 2016

v) Reject companies where related party transactions exceed 25% of sales The filter which was not taken into account by the assessee company is relating to rejection of companies that are affected by some peculiar economic circumstances. It was not lawful for the TPO to reject the search process of the assessee without cogent objections with respect to the choice of filters and consequently the search process carried out by the assessee. A similar view has been upheld in M/s Frigoglass India Pvt. Ltd Vs DCIT [ITA No. 463/Del/2013] and ACIT vs. MSS India (P.) Ltd [ITAT-2009 -32 SOT 132- PUNE], establishing that the search process of the assessee cannot be rejected without cogent reasons.
Income Tax Appellate Tribunal - Delhi Cites 4 - Cited by 13 - Full Document

Colt Technology Services India Pvt. ... vs Assessee on 31 May, 2011

• Colt Technology Services India Pvt. Ltd v Dy CIT • Sum Total Systems (India) Pvt. Ltd v ITO • Adobe Systems India Pvt. Ltd • Genisys Intergrating Systems India Limited • Ameriprise India Pvt. Limited v DCIT • First Advantage Offshore Services Pvt. Ltd. • Agilent Technologies Delhi Considering the above facts and the case laws, the Ld. AR submitted that carrying out the fresh search process without giving the assessee the complete 16 ITA No. 5543/Del/2016 search process is bad in law and not warranted under chapter X of the Act hence, prayed to be rejected.
Income Tax Appellate Tribunal - Delhi Cites 4 - Cited by 1 - Full Document
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