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Bausch & Lomb Eyecare (India) Private ... vs Assessee on 4 March, 2014 cites

Cit vs Ekl Appliances Ltd on 29 March, 2012

5.14. The assessee has also made a plea that the OECD Guidelines permit aggregation of all international transactions with the main activity. Such guidelines, however, are not binding but are merely elucidative. Moreover, Indian is not a member of OECD. The assessee has relied upon the order of the Hon'ble Delhi High court in the case of CIT Vs. EKL Appliances [ITA no. 1068/2011 & 1070/2011). The Hon'ble High Court has rendered its judgment in a specific situation only, where the TPO made wholesale disallowance of the expenditure for the reason that the assessee had suffered continuous losses. This case, therefore, is not applicable as disallowance has not been made in this case on account of expense and having been incurred inspite of continuous losses.
Delhi High Court Cites 16 - Cited by 352 - R V Easwar - Full Document

Commissioner Of Income Tax vs Woodward Governor India Pvt. Ltd. ... on 30 April, 2007

In the case of Indo American Jewellery Ltd. (supra), Hon'ble Bombay High Court while affirming the ITAT decision has held that there being uniformity in assessee's act in not charging interest both from AE and non AE and delay in realization in both the cases is same, , notional interest cannot be considered with ALP on delayed realization.
Delhi High Court Cites 60 - Cited by 492 - S Muralidhar - Full Document
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