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1 - 10 of 21 (0.32 seconds)Section 37 in The Income Tax Act, 1961 [Entire Act]
Section 92CA in The Income Tax Act, 1961 [Entire Act]
The Income Tax Act, 1961
Section 144C in The Income Tax Act, 1961 [Entire Act]
Section 36 in The Income Tax Act, 1961 [Entire Act]
Section 135 in The Companies Act, 2013 [Entire Act]
Section 30 in The Income Tax Act, 1961 [Entire Act]
Reliance Industries Limited, Mumbai vs Acit , Mumbai on 8 March, 2022
ITA 4546/Mum/2024
Royal Canin India Pvt. Ltd
Software Paradigms Infotech (P.) Ltd. v. ACIT (2018) 89 taxmann.com 339 (ITAT
Bangalore)
held that Where Assessing Officer/TPO passed impugned final order of
assessment under section 143(3) read with section 92CA without giving effect to
or carrying out binding directions of DRP as required under section144C(10)
within time specified under section 144C(13), said impugned final order was to be
set aside
7.2. Respectfully reliance is placed on the order of the Hon'ble DelhiHigh Court
wherein the any exercise of powers by the AO in contravention of the specific
directions of the DRP was held to be excessive and hence illegal:
Sony Ericsson Mobile Communication ... vs Commissioner Of Income Tax-Iii on 11 February, 2016
(ii) The test of presence of commercial benefit or no benefit is essentially in the domain of
Section 37 of the Act. The jurisdiction vested under transfer pricing provisions to the TPO is
only to find out whether the prices paid by the services are at Arm's Length Price or not, as
held in Sony Ericson Mobile Communication vs. CIT, 374 ITR 118; CIT vs. EKL Appliances,
(2012) 345 ITR 241 (Del) and many other decisions.