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COURT:
CORAM: ,
SECTION(S):
GENRE:
CATCH WORDS: ,
COUNSEL:
DATE: September 19, 2014 (Date of pronouncement)
DATE: October 4, 2014 (Date of publication)
AY: 2008-09
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CITATION:
Operating Profit to operating Revenue should be taken as the PLI and not Operating Profit to Operating Cost

The purpose of identifying the PLI is to ensure that the comparability of the controlled transactions is objective and reference in this regard was made by him to the OECD Transfer Pricing Guidelines 2010, wherein it was explained that the …

DCIT vs. St. Jude Medical India Pvt. Ltd (ITAT Hyderabad) Read More »

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COURT:
CORAM: ,
SECTION(S): ,
GENRE:
CATCH WORDS: , ,
COUNSEL:
DATE: September 24, 2014 (Date of pronouncement)
DATE: October 4, 2014 (Date of publication)
AY: 2008-09
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CITATION:
No transfer merely because development agreement is entered into

As can be seen from the observations made by CIT(A), he has given specific finding of fact that development agreement has not been acted upon by the developer till date. Therefore, he has concluded that as there is no willingness …

ACIT vs. P. Venkateswara Rao (ITAT Hyderabad) Read More »