S. 92C : Transfer pricing-Arm’s length price-Comparable-Matter remanded-Adjustment for working capital difference nor working provided-Addition is held to be justified.
Open Solutions Software Services Pvt. Ltd. v. Add.CIT (2020) 83 ITR 21 (SN) (Delhi)(Trib.)
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Click here to download the pdf versions of the Digest of case laws S. 92C : Transfer pricing-Arm’s length price-Working capital adjustment granted-Outstanding receivables part of working capital-No separate benchmarking warranted.
Dy. CIT (LTU) v. EXL Service.Com (India) Pvt. Ltd. (2020) 83 ITR 11 (SN) (Delhi)(Trib.)S. 80P : Co-operative societies-Business of Banking and disbursement of agricultural loans-Assessing Officer director to examine each loan disbursement to determine its purpose-Matter remanded. [S. 80P(2)]
Mugu Service Co-Operative Bank Ltd. v. ITO (2020) 83 ITR 85 (SN) (Cochin)(Trib.)S. 80IA : Industrial undertakings -Initial Assessment year-Option given by CBDT to assessee to choose initial Assessment year-Prior period depreciation on investment in premises. [S. 80IA (4)(iv)(a) , 119]
ACIT v. Suma Shilp Ltd. (2020)83 ITR 39 (SN) (Pune)(Trib.)S. 80IA : Industrial undertakings-Infrastructure development- Development, Maintenance and operation of Industrial Park. [S. 80IA(4)(iii)]
Dy. CIT v. Marigold Premises Pvt. Ltd. (2020)83 ITR 32 (SN) (Pune)(Trib.)S. 80IA : Industrial undertakings-Infrastructure development-Container freight station-Eligible for deduction. [S. 80IA(4)]
Ameya Logistics Pvt. Ltd. v. Dy. CIT (2020) 83 ITR 46 (SN) (Mum.)(Trib.)S. 69 : Unexplained investments-Agricultural activity-Purchase of property-Addition is held to not justified. [S. 147, 148]
Raj Devi (Smt.) v. ITO (2020)83 ITR 84 (SN) (Delhi)(Trib.)S. 68 : Cash credit-Cash deposited in bank account-Peak credit-Failure to decide the source of deposit and purpose of withdrawal-Not entitle to benefit of peak credit.
Varun Gupta v. ITO (2020) 83 ITR 82 (SN) (Delhi)(Trib.)S. 68 : Cash credits-Share premium-Valuation report was filed- Assessing Officer failing to examine bank accounts from where investment routed to investigate creditworthiness of creditors, identity of subscribers and genuineness of transaction-Deletion of addition is held to be justified.
ITO v. Aravali Prime Consultants P. Ltd. (2020) 83 ITR 2 (SN) (Jaipur) (Trib.)S. 43B : Deductions on actual payment-Payment of Employees’ contributions to provident fund beyond period stipulated-Allowable as deduction.
Dy. CIT v. Coffee Day Global Ltd. (2020) 83 ITR 41 (SN) (Bang.)(Trib.)