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119 orders · Page 3 of 3
The Tribunal held that the share application money was received in an earlier financial year (2007-08) and therefore, Section 68 was not applicable for the assessment year 2008-09. Section 41(1) was also found to be not attracted.
The Tribunal held that no disallowance can be made for obsolescence of inventory if no provision was created or claimed as a deduction during the year. For the change in inventory valuation method, the matter was remitted to the AO to verify consistent application.
The Tribunal held that no disallowance can be made for obsolescence of inventory if no provision was created or claimed as a deduction during the year. For the change in inventory valuation method, the matter was remitted to the AO to verify consistent application.
The Tribunal held that the Pr. Commissioner's assumption of jurisdiction was valid regarding encroachment and improvement expenses as the Assessing Officer had not conducted proper inquiries. However, the issue of non-taxation of interest income was outside the scope of limited scrutiny.
The Tribunal found that the assessee claimed to have submitted details of its activities, but the CIT(Exemption) did not appear to have analyzed them properly. The Revenue also suggested restoring the matter to the CIT(Exemption) for fresh examination.
The Tribunal held that the TPO erred in considering all direct and indirect costs under RPM and in including two specific comparable companies. The addition should be restricted to international transactions.
For the assessment years where the tax effect was below the CBDT's monetary limit, the Revenue's appeals were dismissed. For other years, the appeals were either dismissed as not pressed by the assessee or remitted back to the Assessing Officer/TPO for fresh adjudication.
The Tribunal held that the disputed comparable company, Universal Print Systems Ltd., was engaged in dissimilar activities and had a significantly different employee cost percentage, making it unsuitable for comparison. Therefore, the matter was remitted for fresh determination.
For the assessment years where the tax effect was below the CBDT's monetary limit, the Revenue's appeals were dismissed. For other years, the appeals were either dismissed as not pressed by the assessee or remitted back to the Assessing Officer/TPO for fresh adjudication.
For the assessment years where the tax effect was below the CBDT's monetary limit, the Revenue's appeals were dismissed. For other years, the appeals were either dismissed as not pressed by the assessee or remitted back to the Assessing Officer/TPO for fresh adjudication.
For the assessment years where the tax effect was below the CBDT's monetary limit, the Revenue's appeals were dismissed. For other years, the appeals were either dismissed as not pressed by the assessee or remitted back to the Assessing Officer/TPO for fresh adjudication.
For the assessment years where the tax effect was below the CBDT's monetary limit, the Revenue's appeals were dismissed. For other years, the appeals were either dismissed as not pressed by the assessee or remitted back to the Assessing Officer/TPO for fresh adjudication.
For the assessment years where the tax effect was below the CBDT's monetary limit, the Revenue's appeals were dismissed. For other years, the appeals were either dismissed as not pressed by the assessee or remitted back to the Assessing Officer/TPO for fresh adjudication.
For the assessment years where the tax effect was below the CBDT's monetary limit, the Revenue's appeals were dismissed. For other years, the appeals were either dismissed as not pressed by the assessee or remitted back to the Assessing Officer/TPO for fresh adjudication.
The Tribunal held that the manufacturing and trading segments are not closely linked transactions and must be benchmarked separately. The assessee's aggregation approach was rejected.
For the assessment years where the tax effect was below the CBDT's monetary limit, the Revenue's appeals were dismissed. For other years, the appeals were either dismissed as not pressed by the assessee or remitted back to the Assessing Officer/TPO for fresh adjudication.
The Tribunal held that the transfer pricing adjustment should be restricted to international transactions with associated enterprises. It also directed re-computation of ALP for certain transactions and excluded a comparable company due to different financial year endings.
The Tribunal held that the transfer pricing adjustment should be restricted to international transactions with associated enterprises. It also directed re-computation of ALP for certain transactions and excluded a comparable company due to different financial year endings.
The Tribunal held that the transfer pricing adjustment should be restricted to international transactions with associated enterprises. It also directed re-computation of ALP for certain transactions and excluded a comparable company due to different financial year endings.