comparable companies on application of TNMM method
and according to RBI data. Vis-à-vis assessment made for assessment year
2005-06, the assessee admitted ... held that rate of royalty approved by SIA/RBI would constitute
CUP data and the transaction would be at arm's length price
processed."
Thus, the approval granted by RBI to SCB was only for
processing of data. Regarding Assessing Officer‟s objection that
assessee has provided ... interests are
protected. He again referred to the approval letter of RBI,
wherein RBI has clearly required SCB India to observe the
following terms
restriction.
The authorities cited on behalf of the writ petitioners and the RBI
suggest that, the statute or a rule has to be looked into ... whose maturity
period goes beyond March 31, 2011 and furnish the data
to RBI within a period of 15 days.
(iv) The data regarding
M/S. Spicer India Limited,, Pune vs Assistant Commissioner Of ... on 10 February, 2017
आयकर
assessee at a rate lesser than 3% as against which the RBI has approved the
rate at 3% for payment of royalty, then the same ... held the rate of royalty approved by SIA / RBI would constitute
cup data and the transaction would be at arm's length price. Accordingly
dated 28/31.01.2003 and initially by the RBI @ 3%.
However, subsequently, the RBI vide communication dated 21.07.2003
accorded automatic approval route to make ... that whether the rate of Royalty
approved by SIA / RBI would constitute CUP data and the transaction is
at arm's length price
further submitted that even otherwise rural branches
have been classified by the RBI based on 1991 census and not based on
7
ITA Nos.1017 ... classification of the rural branches was made by
the RBI based on the data of 1991 census. The Tribunal in the said
decision
Internal Comparable Uncontrolled Price
('CUP') data furnished by the Appellant / reliance placed on RBI
Master Circular).
(d) The Ld. Dispute Resolution Panel
Indian Parliament and
concerns have also been expressed by the RBI on the mounting number of
Non Performing Assets by the day, due to sanctioning ... treated as a separate category as per the RBI guidelines. As per
the data available in Public Domain (Website) relating to the plaintiff
bank (ICICI
shall complete data of refund
orders received from different wards in a floppy on daily basis for
onward transmission to RBI and the third copy
