erred in allowing standard deduction of 5% as per section 92C(2) of the
Act without considering the fact that the provisions of section 92C ... erred in allowing standard deduction of 5% as per section 92C(2)
of the Act without considering the fact that the provisions of section 92C
computing the arm's length price completely ignoring provisions of section
92C(3) of the Act.
(iv) in rejecting the comparable cases without giving ... provisions of
section 92CB of the Act relating to the power of Board along with the
proviso to section 92C(2) squarely applies
chosen by the assessee were accepted by the TPO. Provisions of Section 92C(3) of the
Income-tax Act, lay down the conditions under which ... been
specifically reiterated that the Assessing Officer can have recourse to Section 92C(3) of the Act, only
under the circumstances enumerated under Clauses
erred in not allowing the benefit of ±5% range
as per Section 92C(2) of the Income ... than 10% of their
transactions more operating revenue. However,
than 25% section 92C of the Act read with
Rule 10B of the Income Tax Rules
denying
the (+/-) 5% standard deduction available under proviso to
Section 92C(2) of the Act.
The Appellant prays that the 5% standard deduction ... proviso to Section 92C(2) of the Act be granted to the
Appellant.
I.T.A No. 2811/Ahd/2011 A.Y. 2007-08 Page
Appellant in good faith and as per the provisions of
section 92C of the Act.
12. The learned CIT(A) erred in fact ... defined in section 92B , any
amount is added or disallowed in computing the total income under sub-section (4) of
section 92C , then, the amount
powers conferred by the second proviso to sub-section (2) of section 92C,
the Central Government hereby notifies that where the variation between ... powers conferred by the second proviso to sub-section (2) of section
92C, the Central Government hereby notifies that where the variation between
section 144C(5) of the Act dated 12/09/2011
arising in the assessment order passed under s.143(3) r.w.s.92C ... erred in denying the (+/-) 5% range benefit available under proviso to
Section 920(2) of the Act.
It is prayed that the learned
adjustment of the notional interest under the provisions of
section 92C read with rule 10B of the Income Tax Rules.
4.3 However ... length price in pursuance to the provisions of section 92C
of the Act. The AO accordingly has worked out the amount of interest with respect
facts confirming reliance placed
by AO on proviso to sec. 92C (4) for rejecting deduction ... claimed
u/s 10B of the Act. Both the lower authorities erred in not
appreciating the legal position that proviso to sec. 92C
