seen from the records that the regular assessment u/s 143(3) of the Act
had already been done in the case of the asseseee ... profit
and loss account. Later, the AO issued notice u/s 148 of the Act dated 28th March,
2011 and the reasons recorded
Transfer Pricing
Officer (TPO) u/s 92CA(1) of the Income Tax Act, 1961
(hereinafter called "the Act"). The TPO recommended transfer
pricing ... TNMM. It was further submitted that
the TPO had called for information u/s 133(6) of the Act from the
State Bank of India
M/S. Voith Paper Gmbh, New Delhi vs Ddit, New Delhi on 21 February, 2020
should be excluded while computing profits of business
eligible for deduction under section 10-B and this issue has been decided ... relates to levy of interest under section 234-B of the Act, relying upon the
decision of Hon'ble Supreme Court in the case
furnish the source from where
these figures of the operating profit of MCS Ltd. were obtained.
Needless to mention that AO will allow adequate opportunity ... variation in the margin would be within the permissible range
under Section 92C(2) . However, as we have already set aside the
issue of working
assessee relied on the case of CIT Vs. Dhanrajgirji
Raja Narasinghg irji 91 ITR 544 (SC) wherein it was held that
the department cannot ... case of Dalmia Cement 254 ITR 377
dealing with the issue of Section 37(1) allowances held that
there was a nexus between expenditure
Galileo International Inc. vs Dcit on 30 November, 2007
ORDER
Deepak R. Shah, Accountant Member
initiating the
penalty proceedings against the Appellant under section 271
(1)(c) of the Act."
3. Briefly stated the facts necessary for adjudication ... consulting services
3 Assignment of personnel TNMM 89,91,796
5. The taxpayer in order to benchmark its international
transactions applied Transactional Net Margin
Crocs Inc.,Usa vs Acit, Circle Int. Taxation 1(2)(1), New ... on 16 April
Dcit, New Delhi vs M/S. Ggc Constructions Pvt. Ltd., New ... on 30 July, 2019
