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M/S. I.P. Rings Ltd., Chennai vs Dcit, Chennai on 28 July, 2017
Kumaran Systems Pvt. Ltd., ... vs Dcit Corporate Circle 4(2), Chennai on 9 August, 2021
In this regard, he has relied upon the decision of the
ITAT, Bangalore in the case of M/s.Autodesk (I) P. Ltd., vs. DCIT,
7 I.T.(TP) A. No.95/Chny/2018
[2018] 96 taxmann.com 263 and argued that there are divergent
views on the issue of application of turnover filter but, the
Bangalore Bench of the Tribunal in the latest judgment had
considered all previous judgments and held that high turnover
companies cannot be compared with low turnover companies and
hence, the AO has to apply turnover filter based on Dun and
Bradstreet's analysis for selection of comparables. If turnover filter
is applied, then 4 new companies selected by the AO will go out of
the list of comparables and thus, the margin of the assessee is
within the range of comparables selected by the AO and
consequently addition made towards TP adjustment would also
goes.
H. N. Agri Service Private Limited, ... vs Deputy Commissioner Of Income Tax ... on 31 January, 2023
3.Racmann Springs (P) Ltd Vs. DCIT (1995) 55
ITD0159.TheITAT Delhi Bench has observed that realisation
from Sundry Debtors cannot be treated as cash credits. The
observation of the Bench is reproduced as below: -
"35. The CIT (Appeals) proceeds on the basis that the impugned addition
of Rs. 15,59,845 is made as the assessee was not able to prove the cash
credits. This is evident from para 29 of his order. He speaks of identity
and creditworthiness of the creditors. The Assessing Officer never held
that the said amount represents unproved credits. The Assessing Officer
only held that it represents "undisclosed sales of the assessee". This shows
the utter confusion in the mind of the CIT (Appeals) which led to the
dismissal of the assessee's appeal.
Rgs Printers P.Ltd, Delhi vs Dcit, Central Circle-19, New Delhi on 24 February, 2023
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