3245, 3248 & 3250/Del/2013
document the said details were procured. He accordingly submitted that both legally as
well as factually the addition ... have not explained from which document the said details were
procured. No such document was also seized during the course of search which
incorporates such
milk as per
daily milk procurement sheets and as recorded in the books cannot be
taken, as daily procurement sheets also included purchase of husk ... more logical and rationale. Moreover, though the daily milk
procurement sheets were found but no document was found wherein
the revenue can say that
order to save on transportation
charges, the applicant company were normally procuring the required quantities of
the zinc from the Tarapore (Maharashtra) Depot ... transactions were in cash and no documents related to the purchase of zinc ingots were
being procured by him.
5.2.20 Enquiries from various check posts
Length Price as determined by the
Appellant in the TP documentation maintained by it in terms of
section 92D of the Act read with Rule ... that at the time of creating/ maintaining the TP
documentation, the Appellant could have procured current/ single year
data (i.e. FY 2005-06 data
selected by the Appellant in its
transfer pricing documentation;
(iii) selecting "Global Procurement Consultants Limited" and "TSR
Darashaw" as companies comparable ... consultancy charges and the project
undertaken includes procurement review, procurement advice
and management, procurement governance, bid support services,
performance review, valuation and Finance services, whereas
Procurement of the medicines and supply of the same
specially is directly under the control of the commission agents.
The timely procurement of the medicines ... limited.
k) They are handling the concerned follow-up, documentation,
handling problems related to the procurement, supply on
behalf of the assessee by their
erred on facts and in law in ignoring the chain
of original documents for import of diamonds by Sh. Praveen
Jain/Nilesh Parmar group available ... statement made u/s 132(4) being clinching
evidence of procurement of diamonds from importers for making
2
the genuine supplies from the same
Schedule 7 and shall accede or execute such other documents
to which the Transferring Party is a party;
15 1.3 the transfer complies with ... delivery by CUIH of the relevant share
certificates/title documents and duly executed transfer documents The
31
time limits set out in this Clause shall
which has been verified by Ld.CIT(A) having regards to
documents/evidences/bills etc., filed by assessee. There is nothing
contrary to these observations ... middlemen and commission
agents permitted to operate in purchases or perky procurement
made by government. Thus he emphasised that only business
expenses can be allowed
agent in France
2 ITA No. 4142/Del/2015
for assistance in procuring export orders for the assessee in France. For such
services ... supported by documents filed and settled legal position based on judicial
precedents, held that the said commission paid to foreign agent for
procurement of export
