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M/S Sony Mobile Communications India ... vs Dcit, New Delhi on 6 July, 2018

1.24 The appellants contended that based on the Sony Ruling (Sony India (P) Limited Vs. DCIT (114 ITD 448)) to judge an appropriateness of a comparable, a number of factors are to be seen and their cumulative effect needs to be evaluated. The Tribunal in Sony Ruling has held that even consistent losses alone is not a sufficient reason for excluding a company but the cumulative result of several factors needs to be seen. If a company is not to be rejected ipso-facto on grounds of losses/consistent losses, then diminishing revenue filter stands on an even weaker footing as an indicator of economic distress for a company.
Income Tax Appellate Tribunal - Delhi Cites 23 - Cited by 44 - Full Document
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