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Acit, Cirlce-16(2), Hyd, Hyderabad vs Oakton Global Technology Services ... on 16 December, 2022 cites

Cambridge Technology Enterprises ... vs Dcit, Circle-1(2), Hyd, Hyderabad on 16 December, 2016

2. Contention of the Miscellaneous Applicant is that in respect of the interest on delayed receivables, learned Transfer Pricing Officer ("learned TPO") adopted SBI short term deposit rate as suitable Comparable Uncontrolled Price (CUP) and consequently, the Learned Assessing Officer passed the final assessment order, which was upheld by the learned Dispute Resolution Panel (learned DRP). However, in this case, the Tribunal deleted the Arm's Length Price ("ALP") adjustment. It is argued by the Learned DR that though the Tribunal directed the learned Assessing Officer/learned TPO to consider the index rate in the form of LIBOR+200 basis points in many cases like M/s. Cambridge Technology Enterprises Ltd. Vs. DCIT by order dated 19/11/2019, M/s. OSI Systems Pvt. Ltd. Vs. DCIT by order dated 18/11/2020 and M/s. Albani Molecular Research Centre Pvt. Ltd. Vs. DCIT by order dated 26/11/2020, but surprisingly in this case, the ALP was deleted and according to him, the same constitutes error apparent on record.
Income Tax Appellate Tribunal - Hyderabad Cites 6 - Cited by 9 - Full Document

G.Saraswathi , Nizamabad vs Income Tax Officer, Ward-2, Nizamabad on 19 January, 2021

2. Contention of the Miscellaneous Applicant is that in respect of the interest on delayed receivables, learned Transfer Pricing Officer ("learned TPO") adopted SBI short term deposit rate as suitable Comparable Uncontrolled Price (CUP) and consequently, the Learned Assessing Officer passed the final assessment order, which was upheld by the learned Dispute Resolution Panel (learned DRP). However, in this case, the Tribunal deleted the Arm's Length Price ("ALP") adjustment. It is argued by the Learned DR that though the Tribunal directed the learned Assessing Officer/learned TPO to consider the index rate in the form of LIBOR+200 basis points in many cases like M/s. Cambridge Technology Enterprises Ltd. Vs. DCIT by order dated 19/11/2019, M/s. OSI Systems Pvt. Ltd. Vs. DCIT by order dated 18/11/2020 and M/s. Albani Molecular Research Centre Pvt. Ltd. Vs. DCIT by order dated 26/11/2020, but surprisingly in this case, the ALP was deleted and according to him, the same constitutes error apparent on record.
Income Tax Appellate Tribunal - Hyderabad Cites 0 - Cited by 8 - Full Document

Albany Molecular Research Hyderabad ... vs Dcit, Circle-1(1),, Hyderabad on 24 February, 2020

2. Contention of the Miscellaneous Applicant is that in respect of the interest on delayed receivables, learned Transfer Pricing Officer ("learned TPO") adopted SBI short term deposit rate as suitable Comparable Uncontrolled Price (CUP) and consequently, the Learned Assessing Officer passed the final assessment order, which was upheld by the learned Dispute Resolution Panel (learned DRP). However, in this case, the Tribunal deleted the Arm's Length Price ("ALP") adjustment. It is argued by the Learned DR that though the Tribunal directed the learned Assessing Officer/learned TPO to consider the index rate in the form of LIBOR+200 basis points in many cases like M/s. Cambridge Technology Enterprises Ltd. Vs. DCIT by order dated 19/11/2019, M/s. OSI Systems Pvt. Ltd. Vs. DCIT by order dated 18/11/2020 and M/s. Albani Molecular Research Centre Pvt. Ltd. Vs. DCIT by order dated 26/11/2020, but surprisingly in this case, the ALP was deleted and according to him, the same constitutes error apparent on record.
Income Tax Appellate Tribunal - Hyderabad Cites 0 - Cited by 7 - Full Document

Ghanashyam Mishra And Sons Private ... vs Edelweiss Asset Reconstruction ... on 13 April, 2021

9. Further Hon'ble Apex Court Ghanashyam Mishra & sons Private Limited VS. Edelweiss Asset Reconstruction Company Limited & Ors in IA No. 76416/2021 (M.A. No.1166 of 2021) by order dated 17/8/2022 deprecated the growing tendency of indirectly seeking review of the orders of the Court by filing applications either seeking modification or clarification of the orders.
Supreme Court of India Cites 110 - Cited by 360 - B R Gavai - Full Document
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