M/S. Sava Healthcare Ltd, Pune vs. Assistant Commissioner of Income Tax, Pune
In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method
ITA 1067/PUN/2017[2012-13]Status: DisposedITAT Pune27 Jun 2019AY 2012-13
Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14
For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)
…by Delhi Bench of Tribunal in Louis Vuitton India Retail (P.) Ltd. Vs. DCIT (supra), wherein a contrary view has been taken and reliance was placed on the decision of Hon’ble High Court of Punjab & Haryana in Shri Vishnu Eatables (India) Ltd. Vs. DCIT (2016) 389 ITR 385 (P&H), wherein it was held that failure to supply satisfaction notice to assessee before making reference of international transaction to TPO was at the highest mere irregularity, which does not make reference made void ab-initio. It may also be pointed out that the decision in Hon’ble High Court of Punjab & Haryana was in a Writ Petition. The sa…