S. 144 : Best judgment assessment – Profit in earlier year less than in instant year – GP higher than earlier years – No addition on difference in stock found as on date of search.
Baroda Moulds and Dies v. ACIT (2018) 62 ITR 168 (Ahd)(Trib.)S. 144 : Best judgment assessment – Profit in earlier year less than in instant year – GP higher than earlier years – No addition on difference in stock found as on date of search.
Baroda Moulds and Dies v. ACIT (2018) 62 ITR 168 (Ahd)(Trib.)S. 139 : Return-Revised return – Remanded for verification [S. 139(4)]
Dy. CIT v. L & T Finance Ltd. (2018) 192 TTJ 9 (Mum.)(UO)(Trib.)S. 92C : Transfer pricing – Arms’ length price – Extraordinary event occurred in the case of comparable companies is liable to be excluded. [ S.92CA ]
Conexant Systems Private Ltd. v. Dy. CIT (2018) 63 ITR 320 (Hyd)(Trib.)S. 92C : Transfer pricing – Arms’ length price – Assessee company processed, bottled and sold liquor in India under two segments Bottled in India Scotch (BIIS) and India Made Foreign Liquor (IMFL) – activities of the assessee are two different segments – assessee’s segregation approach for benchmarking these segments justified.
Dy. CIT v. Allied Domecq Spirits and Wine India Pvt. Ltd. (2018) 63 ITR 376/193 TTJ 920 (Delhi) ( Trib.)S. 92C : Transfer pricing -Arm’s length price- Matter was remanded .
CEVA Freight India (P) Ltd. v. Dy. CIT (2018) 192 TTJ 887/ 172 DTR 55 (Delhi)(Trib.)S. 92C:Transfer pricing – Non-charging or under-charging of interest on excess period of credit allowed to AE for realization of invoices amounts to an international transaction and ALP of such an international transaction is required to be determined .
Pitney Bowes Software India (P) Ltd. v. Addl. CIT(2018) 63 ITR 37 (SN)(Delhi ) (Trib))S. 80IB :Industrial undertakings – Manufacture- Conversion of 24 Karat Gold into 22 Karat Gold ornament amounts to manufacturing.[ S.2(29BA)]
ACIT v. Deepak Kumar Handa (2018) 62 ITR 140 (Amritsar)(Trib.)S. 80IA: Industrial undertaking – Survey- Bogus purchases-Additional income offered as non genuine purchases -Entitle deduction [ S.80IA(4), 133A ,147 ]
ACIT v. Mahalaxmi Infraprojects Ltd. (2018) 63 ITR 671 (Pune)(Trib.)S. 80IA : Industrial undertakings – Infrastructure Development – Joint venture between two companies Merely because assessee was paid by Government for development work, it could not be denied deduction u/s 80IA(4) when it provided a complete infrastructure required to support the development of infrastructure facility and deployed its various resources and exposed itself to various risks. [ S.80IA(3), 194C ]
ACIT v. Ho Hup Simplex JV (2018) 63 ITR 74 (SN)(Kol.)(Trib.)S. 79 : Carry forward and set off losses – Change in share holdings – Companies which public are not substantial interested – Unabsorbed depreciation-Business loss was not allowed to be carried forward for the AY. 2007 -08 to 2010-11 [ S.32 ]
Dy. CIT v. Credila Financial Services (2018) 192 TTJ 511/64 ITR 324 / 166 DTR 58 (Mum.)(Trib.)