against which the payments were made.
A. We were exporting tips for ball point pens.
Q. You have made the payment during April ... behind this.
A. My exports to Dubai was consisted mainly of brass tips of ball pen had a real value of Rs. 2 lakhs
assailed.
3. In addition, the assessee was also found to have paid Tips
to its employees during the two years under consideration on
which ... deduction of tax at source was made. The AO
treated such tips to employees as part of `Salaries'. On the
failure of the assessee
default for the short deduction of tax on account of credit tips recovered from
the hotel guest to the employees. Inviting attention to the impugned ... assessee company was in receipt of extra amount known as "TIPS" paid by the
guests in cash or through credit cards
Assessing Officer noted that the assessee has
not deducted tax from the tips paid to the employees. From the various
details furnished by the assessee ... noted that there are three types of
tips i.e. (a) one which is added by the customer in the bills (b) One which
deduction of tax at source on account of banquet
and restaurant tips collected and paid by it to its employees.
She has failed to appreciate ... 2009
holding that the payment of banquet and restaurant tips to the
employees of the assessee in its capacity as employer were
not profits
disallowances made out of business expenditure and
debited under the head tips.
4. That the Ld. CIT(A) has further erred in upholding the
levy ... disallowances made out of business expenditure and
debited under the head tips.
4. That the learned Commissioner of Income Tax
(Appeals) has erred
controlled and uncontrolled transaction and
further the product data compiled in the tips database even after making some
adjustment did not give reliable results ... assessment year 2008 - 09 CUP is the better method
and the tips database was held to be proper. He further submitted that the order
wholly
arbitrary and irrelevant considerations.
V. Application of CUP method using TIPS database
12. That the Id. DRP has grossly erred ... 2021
PCL Foods Pvt. Ltd.
of objections relating to use of TIPS database prices as
comparable data under more direct CUP method.
13. That
granted by
the AE to the assessee.
Application of CUP method using TIPS database
7. That the Id. DRP has grossly erred ... even adjudicating the
grounds of objections relating to application of TIPS
database prices as comparable data under direct method
viz. CUP method
granted by
the AE to the assessee.
Application of CUP method using TIPS database
7. That the Id. DRP has grossly erred ... even adjudicating the
grounds of objections relating to application of TIPS
database prices as comparable data under direct method
viz. CUP method
