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1 - 6 of 6 (0.19 seconds)The Income Tax Act, 1961
Section 92 in The Income Tax Act, 1961 [Entire Act]
Atul Kumar Jain, Meerut vs Ito, Ward-1(1), Meerut on 19 September, 2018
Considering the entire facts and circumstances of the case especially the
quantum addition on enhancement of ALP u/s 92CA(3) deleted by CIT(A)
and acceptance of transfer pricing documentation on similar facts for earlier
assessment years namely 2005-06 to 2007-08 and subsequent A.Y 2010-
11 by AO/TPO, there is no case for levy the penalty u/s 271AA of the I.T.
Act. I rely on the decision in the case of DCIT Vs. Bebo Technologies (P) Ltd.
(2014) 148 ITD 122 (Chd.)(Trib.) while arriving at the above conclusion as
penalty u/s 271AA is not leviable because international -transaction
entered upon by the appellant with its associates concern has been held to
be at. arms length. Accordingly, penalty levied by the assessing officer u/s
14 ITA Nos. 5667, 1799, 2374 & 1800/Del/2015
'271AA is hereby quashed. These grounds of appeals are allowed."
Section 14 in The Income Tax Act, 1961 [Entire Act]
Espn Star Sports Mauritius S.N.C. Et ... vs Addl. Dit, New Delhi on 20 August, 2018
The expenditure has been incurred on promotion of the
product. Therefore, in our considered opinion, the Id. CIT(A) is justified in
deleting the addition. Merely because Mr. Dharam Pal Gulati name comes
to prominence, it cannot be said that the expenditure was not incurred for
the purpose of business. The issue is covered in favour of the assessee by
the decision of ITAT, Mumbai Bench in the case of Star India P. Ltd. Vs
ADIT 103 LTD.73 (Mum.) (TM) wherein it has been held that advertisement
expenses incurred for the business purposes are allowable and it does not
matter that advertisement expenses incurred for the business purposes are
allowable and it does not matter that other party is also benefited by such
advertisement.
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