S.92C: Transfer pricing -Arm’s length price — Exchange rate fluctuations —Taken part of operating margin [ S.92CA ]
Vitech Systems Asia Pvt. Ltd. v. ITO (2020) 81 ITR 58 (SN) (Hyd) (Trib)S.92C: Transfer pricing -Arm’s length price — Exchange rate fluctuations —Taken part of operating margin [ S.92CA ]
Vitech Systems Asia Pvt. Ltd. v. ITO (2020) 81 ITR 58 (SN) (Hyd) (Trib)S.92C: Transfer pricing — Arm’s Length Price — Delay in realisation of trade debts — Uniform policy -Associated enterprises and non- enterprises — Addition of notional interest is held to be not justified . [ S.92B ]
S. Vinodkumar Diamonds P. Ltd. v Dy. CIT (2020) 81 ITR 46 (SN) (Mum) (Trib)S.92C: Transfer pricing — Arm’s length price — Manning service fee —Addition is deleted .
Wilhelmsen Ship Management India Pvt. Ltd. v .Dy. CIT (2020) 81 ITR 14 (SN) ( Mum) (Trib)S. 92C : Transfer pricing – Arm’s length price – Huge related party transactions — Unreliable financials — Not Comparables [
Dy. CIT v. Cadence Design Systems (India) P. Ltd. (2020) 81 ITR 35 (SN) ( Delhi ) (Trib)S. 92C : Transfer pricing – Arm’s length price -A debt-free company — No interest paid to creditor or supplier nor interest earned from unrelated party- Adjustment of interest is held to be not warranted .
Boeing India Pvt. Ltd. v .ACIT (2020)81 ITR 94 (SN) ( Delhi ) (Trib)S. 92C : Transfer pricing – Arm’s length price – Information enabled technology services -Comparable-Extraordinary events taking place in relevant period — Excluded from comparable – Interest receivables – No separate adjustment is required – Denial of exemption is not justified [ S. 10A , 92CA ]
American Express (I) P. Ltd. v. Dy. CIT v (2020) 81 ITR 89 (SN) ( Delhi ) (Trib) .S. 80IA :Industrial undertakings – Infrastructure development-
Generation Of Electricity — Initial assessment year — Not required to notionally reduce losses arising from eligible business in earlier years already set off against other business – Losses arising in eligible business subsequent to earmarking of initial Assessment year to be governed by embargo placed in section 80IA(5) of the Act [ S.70 , 71 ,72 ,80IA(4),80IA(5) ]
S. 69C : Unexplained expenditure – Bogus purchases –
Accommodation entries —Trading in gold jewellery – Enhancement by CIT (A) directing to add entire purchases was deleted – Estimate of 10% of bogus purchases Assessing Officer is affirmed . [ S. 132 ]
S. 69 :Unexplained investments – Silver and jewellery belongs to family members – Declared in the wealth tax return to be considered – Addition is held to be not valid [ S.69A , 132 ]
Pankaj Ladha v. Dy. CIT (2020) 81 ITR 42( SN) (Jaipur) (Trib)S.68: Cash credits — Balances from earlier years – Matter remanded to the Assessing Officer .
Virendra Verma v. ITO (2020) 81 ITR 16 (SN) ( Delhi) (Trib)