property belonged to
the other parties . It is important to highlight the background that these are
assessment pursuant to search and incriminating material was found ... with all the adverse remarks
of the AO more-so with the background that it is an assessment pursuant to
search
Bank,
Liechtenstien which are downloaded from the website, are summarized as
under:-
Background
Millions of Euros belonging to hundreds of citizens living in Germany were ... report on Chiu Fu (Far East) Limited, undated.
59. LGT Background Information/Profile for Maverick Foundation, dated
October 12,2001.
60. LGT Background Information/Profile
apply but such examples are to be
seen against the background of general definition given in
article 5(1) in such a way that examples ... that "[a]s these examples are to be seen against the
background of general definition given in paragraph 1, it is
assumed that
raised in the present appeal."
2.7. In the aforesaid background/factual matrix, the
Hon'ble High Court set aside the issues ... filed by
the assessee and thereafter adjudicate the same. In this
background, the matter was examined by the Tribunal and
was decided against the assessee
lakhs as his "undisclosed income".
5. In this background, the learned counsel explained, with reference to ground No. 3(a) that the business ... present prices, should have been considered in the background of assessee's income and assessee's financial status. In spite of that
amalgamated company which was in existence.
8. In the above background, the case sought to be set-out by the
appellant is that the order ... further legally valid DRP and final
assessment proceedings.
14. In the above background, the Learned Representative submitted that
even though the final assessment order
Shivalik Ventures P. Ltd, Mumbai vs Dcit (Osd-1), Mumbai on 19 September, 2018
IN
raised by the assessee is allowed."
11. In this background, the ld. CIT-DR appearing for the Revenue has
supported the orders ... considering the correct position of law and
facts. In this background, the ld. CIT-DR has made elaborate submissions in
support of the addition made
address the respective Grounds of appeal,
we may briefly refer to the background of the case. The assessee is a
company incorporated under the provisions ... length rate of the Corporate Guarantee Fee. In this
background, the rival Counsels have been heard and the relevant
material perused.
4. First
Before we proceed to adjudicate the respective Grounds of appeal, a
brief background of the case can be summarized as follows. The appellant ... have been viewed as dubious by the assessing
authority. Therefore, in this background, the stand of the Transfer Pricing
Officer in the instant year becomes
