2025 (3) TMI 2195

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....Adv., Ms. Ishita Farasiya, Adv., Ms. Vanshika Taneja, Adv. For the Department : Sh. Vizay B. Vasanta, CIT(DR) ORDER PER SATBEER SINGH GODARA, JM These assessee's twin appeals ITA Nos.6939/Del/2019 and 1694/Del/2022 for assessment years 2015-16 and 2016-17, arise against DCIT, International Taxation, New Delhi's and CIT(A), Delhi's order dated 27.06.2019 and 30.05.2022 having DIN and or....

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....till pending for adjudication before your honors. 1.2. That in facts and circumstances of the case and in law, the Ld. AO erred in ignoring the fact that the transfer pricing issues involved in all years and pending with the appellate authority are repetitive in nature and the Your Honors have already passed an order for AY 2008-09 deleting the entire additions made on similar grounds mad....

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.... penalty of the relevant proceedings in the preceding assessment years wherein it is informed from both sides that the assessee's corresponding appeals in the preceding assessment years stand decided against the department. And that the learned lower authorities had made transfer pricing adjustment(s) involving intra-group services which stand deleted upto to this tribunal and upheld in hon'ble ju....