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DATE: November 7, 2014 (Date of pronouncement)
DATE: November 8, 2014 (Date of publication)
AY: 2008-09
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Though there is a functional difference between a PE Fund and a Merchant Banker, A manager or a sub-advisor to the PE Fund cannot be equated with the PE Fund so as not to be comparable with Merchant Bankers

(i) A merchant bank, apart from helping businessmen in raising finance, also renders consultancy services. It helps its clients in raising finance through issue of shares, debentures, bank loans, etc., from the domestic and international market. The term “Merchant Banker‘ …

Xander Advisors India Pvt. Ltd vs. ACIT (ITAT Delhi) Read More »

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DATE: October 31, 2014 (Date of pronouncement)
DATE: November 4, 2014 (Date of publication)
AY: 2002-03
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CITATION:
If assessee has followed CUP method, it cannot argue at the appellate stage that TNMM should be followed even if TPO has for later years accepted TNMM as the Most Appropriate Method

(i) It is observed that the assessee applied CUP as the most appropriate method for benchmarking the international transactions undertaken by it. The assessee did not dispute before the TPO that the CUP was the most appropriate method. However, it …

DCIT vs. Insilco Ltd (ITAT Delhi) Read More »

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DATE: October 31, 2014 (Date of pronouncement)
DATE: November 3, 2014 (Date of publication)
AY: 2002-03
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CITATION:
(i) Method of applying Resale Price Method (RPM) method, (ii) high advertisement expenses has no bearing on the RPM, (iii) comparables with more than 25% of related party transactions (RPTs) have to be excluded, (iv) transactions which do not impact the profitability should be excluded from the formula, (v) potentially comparable companies cannot be expelled only on the ground of high or low turnover

(i) The assessee simply purchased mobile phones and accessories from Nokia group companies situated outside India and resold the same as such without any further value addition, mainly, to HCL Infosystems in India. Since the goods imported from the foreign …

Nokia India (P) Ltd vs. DCIT (ITAT Delhi) Read More »

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DATE: October 17, 2014 (Date of pronouncement)
DATE: October 21, 2014 (Date of publication)
AY: 2005-06
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CITATION:
Expl 2 to S. 132B, though inserted w.e.f. 1.6.2013, is retrospective and seized cash cannot be adjusted against advance-tax liability

(i) As per provisions of section 132B of the Act the assets seized u/s 132 or requisitioned u/s 132A may be adjusted towards the amount of any “existing liability”. The Explanation 2 to section 132B of the Act inserted by …

DCIT vs. Spaze Tower Pvt. Ltd (ITAT Delhi) Read More »