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1 - 10 of 15 (2.18 seconds)Section 234B in The Income Tax Act, 1961 [Entire Act]
Section 92 in The Income Tax Act, 1961 [Entire Act]
Section 92CA in The Income Tax Act, 1961 [Entire Act]
Section 195 in The Income Tax Act, 1961 [Entire Act]
The Income Tax Act, 1961
Pr. Commissioner Of Income Tax-4, ... vs M/S. Makino India Pvt. Ltd. on 27 January, 2017
16. The ld. counsel for the assessee, however, pointed out that the
Hon'ble Delhi High Court in the case of Pr. CIT v. Ameriprise India Pvt. Ltd.
in ITA No.206/2016, judgment dated 23.03.2016 has taken the following
view:-
Section 115JAA in The Income Tax Act, 1961 [Entire Act]
Section 43B in The Income Tax Act, 1961 [Entire Act]
M/S Te Connectivity Global Shared ... vs Income Tax Officer, Ward-11(1), ... on 13 December, 2017
In this regard, the ld. DR placed reliance on the decision of the
Delhi Bench of the Tribunal in the case of Actis Global Services (P) Ltd. v.
ITO [2017] 81 taxmann.com 457 (Delhi-Trib.) wherein the Tribunal took the
view that the assessee should demonstrate the nature of risk and how the
risk has affected the margin. It was also submitted by the ld. DR that even
quantification of the risk should be made on some basis and cannot be
allowed on an adhoc basis.