method. The plea of the
assessee is that the documents have been subsequently procured and
are necessary for proper ascertainment of T.P. adjustment. Under ... admitted. The
assessee was prevented by sufficient cause as these documents could
not be procured before the assessment proceedings. After having
admitted the additional evidence
documentary evidence was
produced for nature of services rendered and business procured.
No documents were shown to show that M/s. Moderate Credit
Corporation
assessee. It was stated that the assessee could not procure
those documents earlier, therefore, this could not be furnished
before the AO. He requested that ... recording of the statement but later on the assessee
procured the affidavit of Smt. Krishna Yadav widow of Sh.
Chater Singh Yadav and also obtained
time of complying
with the Transfer Pricing ("TP") documentation requirements.
7. The learned AO/TPO/DRP have erred in rejecting following comparable
companies ... country of destination and
the expected date of arrival;
ยท Procure that all necessary shipping documents be collated in the
country of export and be forwarded
China has not maintained any TP Documentation. However, the
analysis is being done on the basis of documentation of Indian
Subsidiary. These are discussed ... functions performed by ZTE India as per TP
Documentations
Trading of Telecom equipment
Procuring equipment from ZTE China
Sale to the Indian customers
Minor incidental
entire period. The
fresh evidences amplifying the seized documents and knitting the seized
documents with each other alongwith copies of bank accounts ... Crores for procurement of land on behalf of said company.
Further, during the course of search operation, certain documents
were found and seized from
exclusion of the
other Transaction Documents, EML: undertakes to Volvo that it
shall not, and shall cause and procure that none of its Connected
Persons
assessee
did not disclose any transaction between inter units. Therefore, these
documents are seized during the course of search and are incriminating
material, which ... disclosure in form 10CCB coupled with seizure of documents showing
transfer of material is an incriminating documents based on which the
assessment u/s 153A
that documents were produced in the form of bills from Uttrakhand Power
Corporation, registration under Central capital Investment Subsidy Schemes
and documents from Pollution Control ... wherein conditions of
tender documents are contained, in which para 5 reads as under:
"You are required to procure, install and commission the
machinery
spare parts
industry, etc. which significantly influence the Appellant's
procurement and pricing decisions.
2. The Hon'ble DRP/ld. TPO erred ... erred in law in rejecting the
transfer pricing documentation maintained by the Appellant
5 ITA No.1801/Del/2014
ITA NO. 6807/Del/2014
