S. 143(3) : Assessment-Validity-Draft order wrongly titled as assessment order–Objection was not raised before DRP-Validity of assessment cannot be challenged. [S. 92CA, 144C]
S. 143(3) : Assessment-Validity-Draft order wrongly titled as assessment order–Objection was not raised before DRP-Validity of assessment cannot be challenged. [S. 92CA, 144C]
S. 115WB : Fringe benefits–Salary–Contribution to approved super annuation fund–Disallowance is held to be justified. [S. 15]
S. 115JB : Book profit– Not applicable to insurance companies.
S. 92C : Transfer pricing-Arm’s Length Price—royalty for use of brand name— Adjustments held to be not justified.
S. 92C : Transfer pricing-Arm’s Length Price—AMP expenses incurred by MSIL could not be treated and categorized as international transaction- No adjustment can be made. [S. 92B]
S. 92C : Transfer Pricing—Arm’s length price—Purchases of cars by assessee from RNAIPL would not come within meaning of international transaction-Marketing expenses-No addition can be made. [S. 92B]
S. 92C : Transfer pricing—adjustment—financial advisory solutions in the field of investment banking division–TNMM method entry level- Effective representation was not made before TPO or CIT(A) –Matter remanded to the AO / TPO.
S. 92C : Transfer Pricing—Transport Segment-Import of raw materials and components-Import of finished goods-and Export of finished goods—Additional evidence was filed-Matter remanded.
S. 92C : Transfer pricing—Comparables—Functionally indifferent companies cannot be selected as good comparable-Asset management company cannot be compared with market support services.
S. 92C : Transfer pricing–Arm’s length price–Notional interest– Loan to AE–Estimate of interest at 11% was held to be not valid when the assessee had charged the interest at 8%-Rule of consistency is followed–Bench mark transaction-Cup method–Adjustment made was deleted–Ad hoc method cannot be applied. [S. 92CA] .