A RAYMOND FASTENERS INDIA PRIVATE LIMITED,PUNE vs. ACIT,CIRCLE-8, PUNE

PDF · subscribers
ITA 311/PUN/2021Status: DisposedITAT Pune16 September 2022AY 2016-179 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal noted that a similar issue for a prior assessment year had been restored to the AO/TPO for fresh adjudication. Following this precedent, the Tribunal restored the current appeal's main issue to the AO/TPO for fresh determination.

What were the facts?

The assessee appealed against the assessment order which increased its total income by making an adjustment for international transactions related to management support services. The core issue was whether these services were genuinely received and if the payment was at arm's length.

What were the issues?

Whether the international transactions for management support services were genuine and if the arm's length price was correctly determined. The appeal also questioned the initiation of penalty and levy of interest.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C,Section 144B,Section 92C,Section 271(1)(c),Section 234A,Section 234B,Section 234C,Section 234D

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “C” BENCH, PUNE

Before: SHRI S.S.GODARA, JM & SHRI G.D. PADMAHSHALI, AM

For Appellant: Shri M.P.Lohia
For Respondent: Shri B.Y.Chavan
Hearing: 30.08.2022Pronounced: 16.09.2022

आदेश की प्रधतधलधप अग्रेधषत / Copy of the Order forwarded to : अपीलाथी / The Appellant. 1. प्रत्यथी / The Respondent. 2. 3. The CIT(A)-National e-Assessment Centre, Delhi. 4. The CIT-3, Pune. धवभागीय प्रधतधनधध, आयकर अपीलीय अधधकरण, “सी” बेंच, 5. पुणे / DR, ITAT, “C” Bench, Pune. गार्ा फ़ाइल / Guard File. आदेशानुसार / BY ORDER, 6. // True Copy //

Senior Private Secretary आयकर अपीलीय अधधकरण, पुणे / ITAT, Pune.

A Raymond Fasteners India P.Ltd., . S.No. Details Date Initials 1 Draft dictated on 02.09.2022 2 Draft placed before author 06.09.2022 Draft proposed & placed before the Second 3 Member 4 Draft discussed/approved by Second Member 5 Approved Draft comes to the Sr. PS/PS 6 Kept for pronouncement on 7 Date of uploading of Order 8 File sent to Bench Clerk 9 Date on which the file goes to the Head Clerk 10 Date on which file goes to the A.R. 11 Date of Dispatch of order

More judgments on Section 144C

All 3,699 judgments and leading authorities on Section 144C →

Recent GST High Court judgments

Search GST case law →