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M/S Yokogawa Ia Technologies India Pvt. ... vs Asst.C.I.T., Bangalore on 8 August, 2018 cites

M/S Te Connectivity Global Shared ... vs Income Tax Officer, Ward-11(1), ... on 13 December, 2017

In this regard, the ld. DR placed reliance on the decision of the Delhi Bench of the Tribunal in the case of Actis Global Services (P) Ltd. v. ITO [2017] 81 taxmann.com 457 (Delhi-Trib.) wherein the Tribunal took the view that the assessee should demonstrate the nature of risk and how the risk has affected the margin. It was also submitted by the ld. DR that even quantification of the risk should be made on some basis and cannot be allowed on an adhoc basis.
Income Tax Appellate Tribunal - Bangalore Cites 8 - Cited by 13 - Full Document

Income-Tax Officer vs Kewal Krishan Sat Pal on 25 March, 1982

In this regard, the dl. Counsel for the assessee has placed reliance on the decision of two High Courts viz., Hon'ble Bombay High Court in the case of CIT v. Gem Plus Jewellery India Ltd. (2010) 194 Taxman 192 (Bom) and Hon'ble Gujarat High Court in the case of ITO v. Kewal Construction, 354 ITR 13 (Guj). In the decision of the Hon'ble Gujarat High Court, it was held that when disallowance u/s. 40(a)(ia) of the Act goes to enhance the profits that are eligible for deduction under Chapter VIA of the Act, the deduction under Chapter VIA should be allowed on such increased profit. This position has also been now confirmed by the CBDT in its ITA Nos. IT(TP)A Nos.466 & 606/Bang/2016 Page 14 of 16 Circular No.37/2016 dated 02.11.2016 wherein the Board has observed as follows:-
Income Tax Appellate Tribunal - Chandigarh Cites 8 - Cited by 7 - Full Document
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