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Documents citing Syniverse Mobile Solutions Pvt. Ltd., ... vs Dcit, Circle-3(2), Hyderabad, ... on 9 November, 2020

Roxtec India Private Limited, New Delhi vs Acit, Circle- 21(2), New Delhi on 22 February, 2021

In M/s. Synverse Mobile Solutions (supra), the Tribunal held that where direct overheads attributable to the respective segments were 10 duly allocated by the assessee to the said segments and even for indirect overheads, allocation was done by applying appropriate allocation keys,in the absence of any objection to the said allocation keys adopted or applied by the assessee, it is not proper for the TPO to resort to the entity level margin comparison of the assessee with other comparables.
Income Tax Appellate Tribunal - Delhi Cites 11 - Cited by 0 - Full Document

Style Solutions Pvt Ltd,New Delhi vs Dcit, Central Circle- 7 , New Delhi on 21 March, 2025

3. Brief facts of the case are that, the assessment proceedings have been initiated against the Assessees pursuant to a search and seizure operation conducted u/s 132/133A of the Income Tax Act, 1961 ('Act' for short) dated 15/02/2014 and subsequent dates in the case of Assessee along with other cases of AMQ Group at various residential and business premises. An approval u/s 153D has been issued by the Joint Commissioner of Income Tax, Central Range- 5, New Delhi vide office letter dated 29/12/2016 pursuant to the office letter of the ACIT, Central Circle-19, New Delhi dated 23/12/2016. Based on the said approval granted u/s 153D of the Act dated 29/12/2016, the assessment proceedings have been initiated u/s 153A r.w. Section 3 ITA Nos. 1020 & 1021/Del/2020 Style Solutions Pvt. Ltd. Vs. DCIT 143(3) of the Act and the assessment orders have been passed against the Assessee for Assessment Year 2008-09 to 2013-14. As against the assessment orders for Assessment Year 2013-14 and 2014-15, which are under challenge before us, the Assessee preferred Appeals before the Ld. CIT(A). The Ld. CIT (A) dismissed the Appeals of the Assessees vide order dated 30/12/2019, which are called in question in the captioned Appeals.
Income Tax Appellate Tribunal - Delhi Cites 15 - Cited by 0 - Full Document
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