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1 - 10 of 14 (3.10 seconds)Section 92CA in The Income Tax Act, 1961 [Entire Act]
Section 92 in The Income Tax Act, 1961 [Entire Act]
The Income Tax Act, 1961
Section 92E in The Income Tax Act, 1961 [Entire Act]
Section 144C in The Income Tax Act, 1961 [Entire Act]
Section 234B in The Income Tax Act, 1961 [Entire Act]
Section 234D in The Income Tax Act, 1961 [Entire Act]
Chartered Accountants Act, 1949
The Commissioner Of Income Tax vs M/S Water'S (India) Pvt Ltd on 20 July, 2010
We however find
that the Hon'ble Bombay High Court in the case of CIT Vs. Pentair Water
India Pvt.Ltd. Tax Appeal No.18 of 2015 judgment dated 16.9.2015 has
taken the view that turnover is a relevant criteria for choosing companies
as comparable companies in determination of ALP in transfer pricing
cases. In doing so the Hon'ble Bombay High Court has followed the
decision of the Hon'ble Delhi High Court in the case of Agnity India
Technologies Pvt.Ltd. (Supra). There is no decision of the jurisdictional
High Court on this issue. In the circumstances, following the principle that
where two views are available on an issue, the view favourable to the
Assessee has to be adopted, we respectfully follow the view of the Hon'ble
Bombay High Court on the issue. Respectfully following the aforesaid
decision, we uphold the order of the DRP excluding 6 companies from the
list of comparable companies chosen by the TPO on the basis of turnover
and size.