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Taegu Tec India Pvt. Ltd.,, Bangalore vs Dcit, Bangalore on 24 May, 2017 cites

Cit vs Ekl Appliances Ltd on 29 March, 2012

6. Being aggrieved, the appellant is before us in the present appeal. It was contended on behalf of the appellant that for the purpose of bench marking the intra group services, TPO was not justified in examining the necessity as well as the profitability of such expenditure ITA No. 1337/Bang/2010 Page 6 of 11 and reliance in this regard was placed on the decision of Hon'ble Delhi High Court in the case of CIT Vs. EKL Appliances 345 ITR 241 and the Coordinate Bench decision cited supra. The learned AR further contended that the learned TPO is not justified in rejecting the TNMM at entity level without demonstrating as to how some other method will be more appropriate for the purpose of bench marking the ALP. He also filed some additional evidence vide an application for admission of additional evidence to demonstrate that the appellant actually received the management services. The additional evidence was in the form of email correspondence and EDP screenshot, etc.
Delhi High Court Cites 16 - Cited by 352 - R V Easwar - Full Document

The Commissioner Of Income-Tax-Iv vs Text Hundred India Pvt. Ltd. on 14 January, 2011

It was contended that the additional evidence may be admitted as the same was necessary for deciding the issue involved in the appeal and reliance in this regard was placed on the decision of Hon'ble Delhi High Court in the case of CIT Vs. Text Hundred India 351 ITR 57 and also relied upon the decision of Hon'ble High Court in the case of CIT Vs. Kum. Satya Setia 143 ITR 486(M.P.). Thus he prayed that the adjustment made by the TPO should be deleted. On other hand the learned DR placed reliance on the order of the lower authorities.
Delhi High Court Cites 9 - Cited by 81 - A K Sikri - Full Document

The Commissioner Of Income Tax vs Kum.A.B.Shanthi Reported In (2002) 255 ... on 18 December, 2007

It was contended that the additional evidence may be admitted as the same was necessary for deciding the issue involved in the appeal and reliance in this regard was placed on the decision of Hon'ble Delhi High Court in the case of CIT Vs. Text Hundred India 351 ITR 57 and also relied upon the decision of Hon'ble High Court in the case of CIT Vs. Kum. Satya Setia 143 ITR 486(M.P.). Thus he prayed that the adjustment made by the TPO should be deleted. On other hand the learned DR placed reliance on the order of the lower authorities.
Madras High Court Cites 25 - Cited by 36 - K R Pandian - Full Document

Eastern Investments Ltd vs Commissioner Of Income-Tax,West ... on 4 May, 1951

7. We heard the rival submissions and perused the material on record. The only issue that arises for consideration in the present appeal is whether the TPO is justified in making ALP adjustment at Nil by holding that there was no necessity of incurring such expenditure and no benefit was derived and there was no proof of actual rendition of services. The TPO treated the transaction of payment of management fee on stand alone basis. No doubt the law is quite settled now. It is beyond the powers of AO/TPO to question the necessity of incurring expenditure or deny the deduction on the ground that no benefit out of such expenditure was incurred. The TPO/AO cannot determine the ALP in such transaction at Nil. The reliance in this regard can be placed on the decision of Hon'ble Delhi High Court in the case of Delhi High Court in the case of EKL Appliances Ltd., 345 ITR 241. The Hon'ble Delhi High Court has reiterated the position laid down by the Hon'ble Supreme Court in the case of Eastern Investment Ltd. v. CIT [1951] 20 ITR 1 (SC) and Sassoon J. David & Co. (P.)
Supreme Court of India Cites 6 - Cited by 340 - V Bose - Full Document
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