that in view of the complexity of the issue and its general importance the question should be considered and decided by a larger Bench ... lease." According to the Bench, "one very important aspect to be kept in view, which was not shown to have been considered
paper book No. 1. Nothing much in this agreement is important for the purpose of this case.
5. Fourthly, a "deed poll ... Department paper book No. 1 Nothing much in this agreement is important for the purpose of this case.
6. Fifthly, on the same
follows :
(a) Whether premium received by the assessee on sale/surrender of import licences is to be included in the total turnover ... India.
2. The assessee firm is engaged in the business of importing of rough diamonds, processing them and exporting of cut and polished diamonds
Transfer Pricing Adjustment of Rs.2.34 crores related
to the Import of Finished Drugs Formulation ('FDFs')
(i.e. Minipress') from ... under:-
SI. AE Transaction Value [Rs. in
crores]
1 5 AEs import of raw materials 6.30
2 3 AEs Export of finished goods
availability of local substitute at cheaper rate assessee had to buy
imported oil. Thus, on the aforesaid basis, the learned Commissioner
(Appeals) ultimately upheld ... submitted,
during the year 1983-84, the Government has imposed ban on import
of tallow which was used by soap manufacture for manufacturing of
soaps
President
1. The assessee is a manufacturer of woollen material from mostly imported wool and exports them. Different grounds of appeal have been raised. These ... from the valuation of the goods in stock since it formed an important element in the total cost of the goods. The value
rebate. It said that 'plant' is a word of wide import and must be broadly construed. It held that 'plant' would ... next ground in asst. yr. 1991-92 relates to taxability of import benefit. This dispute has been raised by the Revenue in ground
alleged
adjustment is subsumed in the adjustment related to the import of finished
goods made by the TPO;
31. Without prejudice to the above, erred ... Alternate Transfer Pricing Adjustment on account of import of finished goods
32. erred in making transfer pricing adjustment
itself. The Supreme Court in the case of CIT v. East West Import & Export (P) Ltd. (1989) 176 ITR 155 (SC) held that ... services have been rendered and the nature of services is not important to decide the issue. What is relevant is the rendering of services
that the assessee is engaged in the business of
export and import of diamonds. It was observed by the AO from the Profit and
Loss ... Tribunal . The learned DR submitted that the assessee is in
business of import and export of diamonds. The assessee has booked forward
contract in foreign
