Alpha Nipon Innovatives Ltd. v. DCIT

291 CTR 309Reported decision2016#20329 most cited
4

judgments rely on this decision, according to BharatTax’s citation analysis of 348,615 Indian tax judgments — from 2018 to 2018.

Judgments citing Alpha Nipon Innovatives Ltd. v. DCIT

Canon India Pvt. Ltd., Gurgaon vs. DCIT, New Delhi

Appeal is dismissed

ITA 832/DEL/2016[2011-12]Status: DisposedITAT Delhi21 Aug 2018AY 2011-12

Bench: Shri R. K. Panda & Ms Suchitra Kamble

Section 143(3)Section 144CSection 92B

…of the circular. The Ld. AR relied on the decision of Hon’ble Punjab and Haryana High Court in the case of Shri Vishnu Etables (India) Ltd. vs. DCIT (2016) 387 ITR 385 and Hon’ble Gujarat High Court in the case of Alpha Nipon Innovatives Ltd. vs. DCIT (2016) 291 CTR 309. In the present case, the TPO had first constructed/determine that the inference of AMP expenditure as a deemed international transaction based upon conjecture and surmises though none existed on facts and law and then arbitrarily determined the ALP of the said international transaction. The Ld. AR submitted that the provisions of the Act provide…

DCIT, New Delhi vs. M/S. Canon India Pvt. Ltd., Gurgaon

Appeal is dismissed

ITA 1052/DEL/2016[2011-12]Status: DisposedITAT Delhi21 Aug 2018AY 2011-12

Bench: Shri R. K. Panda & Ms Suchitra Kamble

Section 143(3)Section 144CSection 92B

…of the circular. The Ld. AR relied on the decision of Hon’ble Punjab and Haryana High Court in the case of Shri Vishnu Etables (India) Ltd. vs. DCIT (2016) 387 ITR 385 and Hon’ble Gujarat High Court in the case of Alpha Nipon Innovatives Ltd. vs. DCIT (2016) 291 CTR 309. In the present case, the TPO had first constructed/determine that the inference of AMP expenditure as a deemed international transaction based upon conjecture and surmises though none existed on facts and law and then arbitrarily determined the ALP of the said international transaction. The Ld. AR submitted that the provisions of the Act provide…

DCIT, New Delhi vs. M/S. Canon India Pvt. Ltd., Gurgaon

Appeal is dismissed

ITA 2275/DEL/2015[2010-11]Status: DisposedITAT Delhi21 Aug 2018AY 2010-11

Bench: Shri R. K. Panda & Ms Suchitra Kamble

Section 143(3)Section 144CSection 92B

…of the circular. The Ld. AR relied on the decision of Hon’ble Punjab and Haryana High Court in the case of Shri Vishnu Etables (India) Ltd. vs. DCIT (2016) 387 ITR 385 and Hon’ble Gujarat High Court in the case of Alpha Nipon Innovatives Ltd. vs. DCIT (2016) 291 CTR 309. In the present case, the TPO had first constructed/determine that the inference of AMP expenditure as a deemed international transaction based upon conjecture and surmises though none existed on facts and law and then arbitrarily determined the ALP of the said international transaction. The Ld. AR submitted that the provisions of the Act provide…

Canon India Pvt. Ltd., Gurgaon vs. DCIT, New Delhi

Appeal is dismissed

ITA 1405/DEL/2015[2010-11]Status: DisposedITAT Delhi21 Aug 2018AY 2010-11

Bench: Shri R. K. Panda & Ms Suchitra Kamble

Section 143(3)Section 144CSection 92B

…of the circular. The Ld. AR relied on the decision of Hon’ble Punjab and Haryana High Court in the case of Shri Vishnu Etables (India) Ltd. vs. DCIT (2016) 387 ITR 385 and Hon’ble Gujarat High Court in the case of Alpha Nipon Innovatives Ltd. vs. DCIT (2016) 291 CTR 309. In the present case, the TPO had first constructed/determine that the inference of AMP expenditure as a deemed international transaction based upon conjecture and surmises though none existed on facts and law and then arbitrarily determined the ALP of the said international transaction. The Ld. AR submitted that the provisions of the Act provide…