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Documents citing India Medtronic Private Limited, ... vs Acit , 10(1)(1), Mumbai on 8 May, 2019

Doowan Electronics India Private ... vs Dcit Circle 1(1), Chennai on 11 November, 2024

38. The perusal of the impugned orders shows that the above cited guidelines by way of decision of this bench of the Tribunal in the case of Skoda Auto India p Ltd (supra) were not available to the revenue authorities. Therefore, we are of the opinion, the issue should be set aside to the files of the TPO with direction to examine the claim of the assessee relating to the import cost factor and :-21-: IT(TP)A. No: 10 & 15/Chny/2024 eliminate the difference if any. However, the TPO/AO/DRP shall see to it that the difference in question is 'likely to materially affect' the price/profit in the open market as envisaged in sub rule (3) of Rule 10B of the Income tax Rules, 1962. Accordingly, ground 4(b) is allowed pro tanto."
Income Tax Appellate Tribunal - Chennai Cites 4 - Cited by 0 - Full Document

Assistant Commissioner Of Income-Tax, ... vs Doowon Electronics India Private ... on 11 November, 2024

38. The perusal of the impugned orders shows that the above cited guidelines by way of decision of this bench of the Tribunal in the case of Skoda Auto India p Ltd (supra) were not available to the revenue authorities. Therefore, we are of the opinion, the issue should be set aside to the files of the TPO with direction to examine the claim of the assessee relating to the import cost factor and :-21-: IT(TP)A. No: 10 & 15/Chny/2024 eliminate the difference if any. However, the TPO/AO/DRP shall see to it that the difference in question is 'likely to materially affect' the price/profit in the open market as envisaged in sub rule (3) of Rule 10B of the Income tax Rules, 1962. Accordingly, ground 4(b) is allowed pro tanto."
Income Tax Appellate Tribunal - Chennai Cites 4 - Cited by 0 - Full Document
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