S.92CA: Transfer pricing-Reference to Transfer Pricing Officer-Arm’s Length Price-Appropriate method-Transactional Net Margin Method (TNMM)-Resale Price Method (RPM)-No material difference-Tribunal order deleting adjustment affirmed.[S.92C, 260A]
S.92CA: Transfer pricing-Reference to Transfer Pricing Officer-Arm’s Length Price-Appropriate method-Transactional Net Margin Method (TNMM)-Resale Price Method (RPM)-No material difference-Tribunal order deleting adjustment affirmed.[S.92C, 260A]
S. 92C : Transfer pricing-Risk adjustment-Tribunal remitted matter for risk adjustment margin-Revenue appeal not maintainable as issue not raised earlier. [S. 260A]
S. 92C : Transfer pricing-CUP method-TPO adopting CUP method unjustified where in subsequent years assessee’s benchmarking method was accepted-Order of Tribunal affirmed. [S. 260A]
S. 92C : Transfer pricing-Arm’s length price-Tribunal after giving detailed reasons rejected comparables selected by TPO-No question of law arose for consideration. [S. 260A]
S. 90 : Double taxation relief-Interpretation of agreements-Matter covered by Supreme Court-Writ petition was dismissed.[Art. 226]
S. 90 :Double taxation relief-Interpretation of agreements-Matter covered by Supreme Court-Writ petition was dismissed-SLP of assessee dismissed. [Art.136]
S. 69C: Unexplained expenditure-Bogus purchases-Restricting addition to the extend of seven percentage of alleged bogus purchases-No question of law-Order of Tribunal was affirmed. [S.37(1), 69C, 260A].
S. 69C: Unexplained expenditure-Bogus purchases-Information from sales tax department-Suspicious dealers-Only profit attributable on total purchase consideration could be subject to income-tax-Not entire purchase.[S. 260A]
S. 69C : Unexplained expenditure-Bogus purchases-Tribunal justified in restricting addition to 8% GP on impugned purchases, as purchases were genuine and paid by cheque. [S. 133(6),
260A]
S. 69C : Unexplained expenditure-Bogus purchases-No discrepancy between purchases and sales-Entire bogus purchases could not be treated as income; addition restricted to GP element. [S. 260A]