Honda Trading Corporation India Pvt. Ltd. vs DCIT/ ACIT
Parties Involved
Facts Summary
The assessee, Honda Trading Corporation India Pvt. Ltd., filed its return of income for AY 2021-22 declaring total income of Rs. 9,78,20,290/-. The case was selected for Complete Scrutiny through CASS. The assessee was primarily engaged in trading activities and service activities both in India and international markets. The AO referred the case to TPO due to TP risk parameters. The TPO proposed an adjustment of Rs. 12,49,16,249/- relating to the trading segment, which was later reduced to Rs. 11,57,97,707/-. The assessee appealed against this adjustment. Subsequently, the AO made an additional adjustment of Rs. 2,57,67,740/- on account of differential commission paid and received, which the assessee also appealed against.…
Decision in favour of
Assessee
Legal Issues
- 1. Adjustment of Rs. 11,57,97,707/- on account of trading segment
- 2. Adjustment of Rs. 2,57,67,740/- on account of differential commission paid/received
- 3. Interest levied under sections 234A, 234B, and 234C
- 4. Penalty proceedings under section 270A
Judgment Outcome
Decided in favour of Assessee.
Precedents Relied Upon
7 precedents cited in this judgement.
Similar Judgements
Idemitsu Lube India Private Limited vs. DCIT Circle 10(1)
Delhi Bench 'H', New Delhi benchAY 2021-22Partly AllowedIdemitsu Lube India Private Limited vs. DCIT
Delhi Bench ‘H’ benchAY 2020-21AllowedMaersk Tankers India Private Limited Vs. ACIT Circle
Mumbai benchAY 2022-23AllowedOSI Energy Automation India Private Ltd. vs. The Deputy Commissioner of Income Tax
Bangalore benchAY 2021-22Partly AllowedRajasthan Prime Steel Processing Center Pvt. Ltd. Vs. DCIT
Delhi Bench ‘H’ benchAY 2009-10 & 2010-11Partly AllowedNoida Towers Private Limited vs. Assessment Unit