S. 92C : Transfer pricing-Arm’s length price-Purchase of sap licence-Details submitted but authorities failing to consider-Application of benefit test instead of methodology set out in Act and rules not sustainable. [R. 10B]
S. 92C : Transfer pricing-Arm’s length price-Purchase of sap licence-Details submitted but authorities failing to consider-Application of benefit test instead of methodology set out in Act and rules not sustainable. [R. 10B]
S. 92C : Transfer pricing-Arm’s length price–Transactional Net Margin Method-Selection of comparables-Tribunal for the earlier year directing exclusion of all companies having annual turnover less than Rs. 5 crores in Information Technology enabled services segment-Order of Transfer Pricing Officer including company having turnover below Rs. 5 Crores from Segment-Not justified. [S. 92CA]
S. 92C : Transfer pricing-Arm’s length price-Rendering business support services-Reimbursement with mark-up-Matter remanded to CIT(A) for adjudication de novo.
S. 92C : Transfer pricing-Arm’s length price-Rendering business support services-Reimbursement with mark-up-Matter remanded to CIT(A) for adjudication de novo.
S. 92B : Transfer pricing-Arm’s Length Price-Provision of corporate guarantee to associated enterprise-International Transaction-Order of CIT(A) is affirmed. [S. 92C]
S. 80P : Co-operative societies-Interest earned on money deposited in Nationalised Bank-Taxable as income from other sources-Interest earned on securities with Reserve Bank of India-Eligible for exemption-Enhanced business profits on account of disallowances-Qualify for exemption-Members includes nominal members and extraordinary members-Eligible for exemption. [S. 56, 80P(2)(a)(i), Maharashtra Co-operative Societies Act, 1960]
S. 80IA : Industrial undertakings-Infrastructure development-Initial assessment Year-Option to choose with assessee-Deduction to be computed without setting off unabsorbed Depreciation-Windmill-Expenditure were incurred for effective functioning of Windmills-Depreciation allowable. [S. 32, 80IA(2)]
S. 69C : Unexplained expenditure-Bogus purchases-Accommodation entries-CIT(A) estimated at 25 percent-Tribunal restricted the addition to 12.5 percent.
S. 69 : Unexplained investments-Deposit of cash in bank account-Addition was deleted-Cash deposits and withdrawal-Concealment penalty-Matter remanded. [S. 271(1)(c)]
S. 69 : Income from undisclosed sources-Entries in cash book on date of issue of cheque-Presented in Bank subsequently-Matter remanded for verification.