S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Sale of goods to associated enterprises-Comparative-Matter remanded to the Assessing Officer .
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Sale of goods to associated enterprises-Comparative-Matter remanded to the Assessing Officer .
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Interest on delayed receivables-To Be Benchmarked Applying State Bank Of India Short-Term Deposit Interest Rate For Year-No Material To Show Grace Period Allowed By Assessee To Associated Enterprise-Assessing Officer Granting 30 Days-Proper. [S. 92B, 92F(v)]
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Expenses allocated on cost-to-cost basis-Transfer pricing adjustments deleted-Tax effect less than prescribed limit of Rs. 50 Lakhs-Appeal of Revenue is held to be not maintainable . [ S.92CA , 253(1) ]
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Corporate guarantee-Standby Letter of credit-Acquisition not taking place and entities not becoming Associated Enterprises-No requirement of benchmarking needed-Transfer Pricing adjustment is deleted-Interest on outstanding receivables from Associated Enterprises-Benchmarked separately-If bills realised beyond granted credit period interest to be imputed on bills . [ S.92B, 234D,244A ]
S. 92C: Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Corporate guarantee-Transaction to be benchmarked adopting 0.5 Per Cent. [ S.92B]
S. 69A : Unexplained money-Cash deposited in the bank account-Merely on the basis of statement of purchaser addition is not valid-Reassessment is valid. [S. 148, 151]
S. 69A : Unexplained money-Surrender in the course of survey-Business income-Income cannot be taxed at special rate. [S. 115BBE]
S. 69A: Unexplained money-Amount withdrawn-No evidence to justify deposit-Addition is justified.
S. 68 : Cash credits-Unexplained expenditure-Unsecured loans-Banking channel , account confirmation , Permanent Account Numbers , Bank statements and income-tax returns furnished-Addition is not justified-Interest expenses cannot be disallowed . [ S.69C ]
S. 68: Cash credits-Long-term capital gains-Penny stock-Information from investigation wing-Sale of shares through stock exchange and consideration received through stock broker in banking channels-Copies of physical share certificates produced-Sale consideration cannot be considered as unexplained cash credit-Entitle to exemption. [ S.10(38), 45 ]