powers u/s 144C(8) of ITA, 1961.
ITA Nos.1062 to 1068/PUN/2017
3
Sava Healthcare Ltd.
Requirements u/s 92C ... appreciating that no any opinion, as so envisaged in section 92C(3) , as
regards profit passing, etc. was reached by the then AO, before making
defined under section 92B , which has two sub-
sections. The first sub-section talks of actual international transaction and the second
sub-section refers ... Meaning of international transaction.--(1) For the purposes of this section and
sections 92 , 92C , 92D and 92E , "international transaction" means atransaction
between
only if any of the four conditions stipulated in section 92C(3) are
fulfilled and not otherwise; (iv) the assessee has given detail reason ... lastly, the
assessee submitted that in view of proviso to section 92C(2) , the
operating margin of the comparables and the operating profit disclosed
erred in not using any of the five method prescribed under section 92C to
benchmark the international transaction of payment for availing of services ... length
price by following one of the methods provided in Sec. 92C of the Act. As
observed by us hereinabove, it is a matter
benefit of +/-
5 % range, as provided in the proviso to section 92C(2) of the Act.
5. That on facts ... other and the
proceedings under section 92CA (1) of the act are not
dependent on the proceedings under section 92C
defined
under section 92B , which has two sub-sections. The first sub-section talks of
actual international transaction and the second sub-section refers ... Meaning of international transaction.--(1) For the purposes of this
section and sections 92 , 92C , 92D and 92E , "international transaction"
means atransaction between
other method as prescribed by Board in terms of
Section 92C(i) of the Act" for computing the ALP. The TPO vide its order ... mentioned
in clause (ii) of section 92F which is reproduced herein below:
92F. In sections 92 , 92A , 928, 92C , 920 and 92 £, unless the cornea
other method as prescribed by Board in terms of
Section 92C(i) of the Act" for computing the ALP. The TPO vide its order ... mentioned
in clause (ii) of section 92F which is reproduced herein below:
92F. In sections 92 , 92A , 928, 92C , 920 and 92 £, unless the cornea
other method as prescribed by Board in terms of
Section 92C(i) of the Act" for computing the ALP. The TPO vide its order ... mentioned
in clause (ii) of section 92F which is reproduced herein below:
92F. In sections 92 , 92A , 928, 92C , 920 and 92 £, unless the cornea
international transactionshall be computed
having regard to the ALP and Section 92C (1) which setsout
the different methods of determining the ALP, makes it clear ... Section 928
defines'international transaction' as under:
"Meaning of international transaction. 928.(1) For the
purposes of this sectionand sections 92 , 92C
