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Documents citing Yum! Restaurants Marketing Pvt. Ltd., ... vs Ito, Ward- 27(4), New Delhi on 9 September, 2019

Epson India Private Limited, Ulsoor vs Deputy Commissioner Of Income Tax, ... on 14 July, 2022

22.4 We have perused submissions advanced by both sides in light of records placed before us including the decision relied upon by Ld.AR in case of Huawei Technologies India Pvt. Ltd. (supra). 22.5 A reading of Rule 10B(l)(e)(iii) of the Rules read with sec. 92CA of the Act, would clearly shows that the net profit margin arising in comparable uncontrolled transactions has to be adjusted to take into account the differences, if any, between the international transaction and the comparable uncontrolled transactions, which could materially affect the amount of net profit margin in the open market.
Income Tax Appellate Tribunal - Bangalore Cites 5 - Cited by 0 - Full Document

Income Tax Officer Ward 4 (3), Jalandhar vs Smt. Gurjeet Kaur W/O Sh. Kulwant Singh, ... on 15 November, 2022

4. We have heard both the sides and perusal of the record. Admittedly, in this case the addition has been deleted in the quantum proceedings by the ITAT Amritsar Bench in ITA Nos. 627 & 628/Asr/2017 vide order dated 21.02.2022. The issue raised by the Revenue is that time for filing further appeal before the Hon'ble High Court was yet available and the Hon'ble High Court may restored/partly restore the order of the Assessing Officer and hence no adjudication by CIT(A) on merits against the penalty order would be available. In our view, the issue raised by the Revenue would not survive because the very addition farming the basis of penalty has been deleted by the coordinate bench. We, therefore, concur with the finding of the ld. CIT(A) who has rightly deleted the penalty u/s 271(1)(c) of the Act. This view of ours gets support from the judgment of 4 ITA No. 124 /Asr/2022 ITO v. Gurjeet Kaur the ITAT Tribunal Bench in the case of ITO v. Deepa Restaurant & Bar Pvt. Ltd. in ITA No. 5424/Mum/2012.
Income Tax Appellate Tribunal - Amritsar Cites 10 - Cited by 0 - Full Document
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