What is Tweezerman (India) P. Ltd. v. Addl. CIT authority for?

An Assessing Officer cannot reduce eligible profits under section 80-IA(10) read with section 10B(7) based on an arm's length price determined by the Transfer Pricing Officer without demonstrating how that price was determined.

How many judgments cite Tweezerman (India) P. Ltd. v. Addl. CIT?

28 judgments on BharatTax cite Tweezerman (India) P. Ltd. v. Addl. CIT (133 TTJ 308), spanning 2019 to 2022.

Tweezerman (India) P. Ltd. v. Addl. CIT (133 TTJ 308)

EATON TECHNOLOGIES PVT.LTD,,PUNE vs. PR. COMMISSIONER OF INCOME-TAX-1,, PUNE

ITA 902/PUN/2018[2011-12]Status: DisposedITAT Pune06 Dec 2022AY 2011-12

Bench: Shri S.S.Godara & G.D.Padmahshaliआयकरअपीलसं. / Ita No.590/Pun/2018 िनधा"रण वष" / Assessment Year: 2014-15 Eaton Technologies Private Limited, Dcit, Circle-1(2), Cluster C, Wing 1, Eon Free Zone, Vs Pune Plot No.1, Sr.No.77, Midc Kharadi Knowledge Park, Kharadi, Pune 411 014 Pan : Aabce4323Q Appellant/ Assessee Respondent /Revenue आयकरअपीलसं. / Ita No.902/Pun/2018 िनधा"रण वष" / Assessment Year: 2011-12 Eaton Technologies Private Limited, Pr.Cit-1, Cluster C, Wing 1, Eon Free Zone, Vs Pune Plot No.1, Sr.No.77, Midc Kharadi Knowledge Park, Kharadi, Pune 411 014 Pan : Aabce4323Q Appellant/ Assessee Respondent /Revenue

Section 10ASection 143(3)Section 14ASection 40Section 80I

…the Transfer Pricing Officer. In fact these issues have already been considered in various orders of the Tribunal. The Income-tax Appellate Tribunal, Chennai "A" Bench in the case of Tweezerman (India) P. Ltd. v. Addl. CIT [2010] 4 ITR (Trib) 130 (Chennai) (133 TTJ 308) has considered the matter in detail and held that the reduction of eligible profits of an assessee as done by the Assessing Officer by invoking the provisions of section 80- IA(10) read with section 10B(7), in the context of the Transfer Pricing Officer's order is unsustainable. The Tribunal has held that the Assessing Officer was not justified…

EATON TECHNOLOGIES PVT.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(2),, PUNE

ITA 590/PUN/2018[2014-15]Status: DisposedITAT Pune06 Dec 2022AY 2014-15

Bench: Shri S.S.Godara & G.D.Padmahshaliआयकरअपीलसं. / Ita No.590/Pun/2018 िनधा"रण वष" / Assessment Year: 2014-15 Eaton Technologies Private Limited, Dcit, Circle-1(2), Cluster C, Wing 1, Eon Free Zone, Vs Pune Plot No.1, Sr.No.77, Midc Kharadi Knowledge Park, Kharadi, Pune 411 014 Pan : Aabce4323Q Appellant/ Assessee Respondent /Revenue आयकरअपीलसं. / Ita No.902/Pun/2018 िनधा"रण वष" / Assessment Year: 2011-12 Eaton Technologies Private Limited, Pr.Cit-1, Cluster C, Wing 1, Eon Free Zone, Vs Pune Plot No.1, Sr.No.77, Midc Kharadi Knowledge Park, Kharadi, Pune 411 014 Pan : Aabce4323Q Appellant/ Assessee Respondent /Revenue

Section 10ASection 143(3)Section 14ASection 40Section 80I

…the Transfer Pricing Officer. In fact these issues have already been considered in various orders of the Tribunal. The Income-tax Appellate Tribunal, Chennai "A" Bench in the case of Tweezerman (India) P. Ltd. v. Addl. CIT [2010] 4 ITR (Trib) 130 (Chennai) (133 TTJ 308) has considered the matter in detail and held that the reduction of eligible profits of an assessee as done by the Assessing Officer by invoking the provisions of section 80- IA(10) read with section 10B(7), in the context of the Transfer Pricing Officer's order is unsustainable. The Tribunal has held that the Assessing Officer was not justified…

DEPUTY COMMISSIONER OF INCOME TAX CIR 1(1), PUNE vs. EATON TECHNOLOGIES PVT. LTD.,, PUNE

Appeals are partly allowed for statistical purpose in above terms

ITA 43/PUN/2021[2016-17]Status: DisposedITAT Pune07 Jul 2022AY 2016-17

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita Nos.42 & 43/Pun/2021 िनधा"रणवष" / Assessment Years : 2015-16 & 16-17 Dcit, Circle-1(1), Pune. M/S.Eaton Technologies Pvt. Ltd., Vs Cluster C Wing-1, Eon Zone, Midc Kharadi, Knowledge Park, Plot No.1, Survey No.77, Kharadi, Pune – 411014. Pan: Aabce 4323 Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Vishal Kalra & Shri Ss Tomar -Ar Revenue By Shri Sunil Kumar – Cit(Dr) Date Of Hearing 24/06/2022 Date Of Pronouncement 07/07/2022 आदेश/ Order Per S.S.Godara, Jm: These Revenue’S Twin Appeals For The Assessment Years 2015- 16 & 2016-17 Arise Against The Cit(A)-13, Pune’S Separate Orders; Both Dated 29.05.2020, Passed In Case No.Pn/Cit(A)-13/Dcit, Circle-1(2), Pune/10142/2019-20/02, Pn/Cit(A)-13/Dcit, Circle- 1(2), Pune/10142/2019-20/03 Respectively, Involving Proceedings Under Section 143(3) Of The Income Tax Act, 1961. Heard Both The Parties. Case Files Perused.

Section 10Section 10ASection 143(3)Section 14ASection 40Section 80ISection 9(1)(vi)

…f the Tribunal. The Income-tax Appellate Tribunal, Chennai "A" Bench in the case of Tweezerman (India) ITA Nos.42 & 43/PUN/2021 for A.Y’s: 2015-16 & 16-17 DCIT Vs. M/s.Eaton Technologies Pvt. Ltd., (R) P. Ltd. v. Addl. CIT [2010] 4 ITR (Trib) 130 (Chennai) (133 TTJ 308) has considered the matter in detail and held that the reduction of eligible profits of an assessee as done by the Assessing Officer by invoking the provisions of section 80-IA(10) read with section 10B(7), in the context of the Transfer Pricing Officer's order is unsustainable. The Tribunal has held that the Assessing Officer was not justified t…

DEPUTY COMMISSIONER OF INCOME TAX CIR 1(1), PUNE vs. EATON TECHNOLOGIES PVT. LTD.,, PUNE

Appeals are partly allowed for statistical purpose in above terms

ITA 42/PUN/2021[2015-16]Status: DisposedITAT Pune07 Jul 2022AY 2015-16

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita Nos.42 & 43/Pun/2021 िनधा"रणवष" / Assessment Years : 2015-16 & 16-17 Dcit, Circle-1(1), Pune. M/S.Eaton Technologies Pvt. Ltd., Vs Cluster C Wing-1, Eon Zone, Midc Kharadi, Knowledge Park, Plot No.1, Survey No.77, Kharadi, Pune – 411014. Pan: Aabce 4323 Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Vishal Kalra & Shri Ss Tomar -Ar Revenue By Shri Sunil Kumar – Cit(Dr) Date Of Hearing 24/06/2022 Date Of Pronouncement 07/07/2022 आदेश/ Order Per S.S.Godara, Jm: These Revenue’S Twin Appeals For The Assessment Years 2015- 16 & 2016-17 Arise Against The Cit(A)-13, Pune’S Separate Orders; Both Dated 29.05.2020, Passed In Case No.Pn/Cit(A)-13/Dcit, Circle-1(2), Pune/10142/2019-20/02, Pn/Cit(A)-13/Dcit, Circle- 1(2), Pune/10142/2019-20/03 Respectively, Involving Proceedings Under Section 143(3) Of The Income Tax Act, 1961. Heard Both The Parties. Case Files Perused.

Section 10Section 10ASection 143(3)Section 14ASection 40Section 80ISection 9(1)(vi)

…f the Tribunal. The Income-tax Appellate Tribunal, Chennai "A" Bench in the case of Tweezerman (India) ITA Nos.42 & 43/PUN/2021 for A.Y’s: 2015-16 & 16-17 DCIT Vs. M/s.Eaton Technologies Pvt. Ltd., (R) P. Ltd. v. Addl. CIT [2010] 4 ITR (Trib) 130 (Chennai) (133 TTJ 308) has considered the matter in detail and held that the reduction of eligible profits of an assessee as done by the Assessing Officer by invoking the provisions of section 80-IA(10) read with section 10B(7), in the context of the Transfer Pricing Officer's order is unsustainable. The Tribunal has held that the Assessing Officer was not justified t…

DEPUTY COMMISSIONER OF INCOME TAX, PUNE vs. HALLIBURTON TECHNOLOGY INDIA PVT. LTD, PUNE

In the result, the appeal of the Revenue is dismissed

ITA 277/PUN/2021[2011-12]Status: DisposedITAT Pune10 Jun 2022AY 2011-12

Bench: Invoking Section 80La( 10) , Of The Act When Bare Reading Of The Provision Does Not Impose Such Burden Of Proving Tax Avoidance On A.O.? 3. Whether On The Facts, Circumstances Of The Case And- In Law, Ld. Commissioner Of Income Tax (Appeals) Was Justified In Interpreting The Words According To The Object Of The Provision Ignoring The Fundamental Principle Of Interpretation Of Stature That Nothing Should Be Added To The Words Used By Legislature? 4. Whether On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Was Justified In Imposing Burden Of Proving Tax Avoidance Ignoring The Fact That Section 80Ia(10) Of The Act Is A “Domestic Transfer Pricing” Provision & Proving Tax Avoidance Is Not One

For Appellant: Shri Arvind DesaiFor Respondent: Shri Niraj Agarwal

Section 108Section 10ASection 10B(7)Section 115JSection 143(3)Section 80ISection 80l

…the Transfer Pricing Officer. In fact these issues have already been considered in various orders of the Tribunal. The Income-tax Appellate Tribunal, Chennai "A" Bench in the case of Tweezerman (India) P. Ltd. v. Addl. CIT [2010] 4 ITR (Trib) 130 (Chennai) (133 TTJ 308) has considered the matter in detail and held that the reduction of eligible profits of an assessee as done by the Assessing Officer by invoking the provisions of section 80-IA(10) read with section 10B(7), in the context of the Transfer Pricing Officer's order is unsustainable. The Tribunal has held that the Assessing Officer was not justified t…

EATON TECHNOLOGIES PVT.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(2),, PUNE

Appeal is partly allowed in above terms

ITA 3075/PUN/2017[2013-14]Status: DisposedITAT Pune10 May 2022AY 2013-14

Bench: Shri S. S. Godara, Jm & Shri Dr. Dipak P. Ripote, Am आयकर अपीऱ सं. / Ita No.3075/Pun/2017 ननधधारण वषा / Assessment Year : 2013-14 Eaton Technologies Pvt. Ltd. Cluster C, Wing 1, Eon Free Zone, Plot No.1, Sr. No.77, Midc Kharadi Knowledge Park, Kharadi ,Pune- 411 014. .......अपऩलधथी / Appellant Pan : Aabce4323Q बनधम / V/S. ……प्रत्यथी / Respondent Dcit, Circle-1(2), Pune Assessee By : Shri Vishal Karla Revenue By : Shri S. P. Walimbe

For Appellant: Shri Vishal KarlaFor Respondent: Shri S. P. Walimbe

Section 10ASection 143(3)Section 144C(8)Section 40Section 80ISection 92C

…f the Transfer Pricing Officer. In fact these issues have already been considered in various orders of the Tribunal. The Income-tax Appellate Tribunal, Chennai "A" Bench in the case of Tweezerman (India) P. Ltd. v. Addl. CIT [2010] 4 ITR (Trib) 130 (Chennai) (133 TTJ 308) has considered the matter in detail and held that the reduction of eligible profits of an assessee as done by the Assessing Officer by invoking the provisions of section 80-IA(10) read with section 10B(7), in the context of the Transfer Pricing Officer's order is unsustainable. The Tribunal has held that the Assessing Officer was not justified t…

DEPUTY COMMISSIONER OF INCOME-TAX vs. M/S. HONEYWELL AUTOMATION INDIA LTD.,, PUNE

In the result, the appeal of Revenue is dismissed as infructuous

ITA 620/PUN/2015[2005-06]Status: DisposedITAT Pune03 Jun 2021AY 2005-06

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

For Appellant: Shri Ajit Kumar JainFor Respondent: S/Shri Kalika Singh &

Section 10ASection 10A(7)Section 251(2)

…f the Transfer Pricing Officer. In fact these issues have already been considered in various orders of the Tribunal. The Income-tax Appellate Tribunal, Chennai "A" Bench in the case of Tweezerman (India) P. Ltd. v. Addl. CIT [2010] 4 ITR (Trib) 130 (Chennai) (133 TTJ 308) has considered the matter in detail and held that the reduction of eligible profits of an assessee as done by the Assessing Officer by invoking the provisions of section 80- IA(10) read with section 10B(7), in the context of the Transfer Pricing Officer's order is unsustainable. The Tribunal has held that the Assessing Officer was not justified…

M/S. HONEWELL AUTOMATION INDIA LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of Revenue is dismissed as infructuous

ITA 584/PUN/2015[2005-06]Status: DisposedITAT Pune03 Jun 2021AY 2005-06

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

For Appellant: Shri Ajit Kumar JainFor Respondent: S/Shri Kalika Singh &

Section 10ASection 10A(7)Section 251(2)

…f the Transfer Pricing Officer. In fact these issues have already been considered in various orders of the Tribunal. The Income-tax Appellate Tribunal, Chennai "A" Bench in the case of Tweezerman (India) P. Ltd. v. Addl. CIT [2010] 4 ITR (Trib) 130 (Chennai) (133 TTJ 308) has considered the matter in detail and held that the reduction of eligible profits of an assessee as done by the Assessing Officer by invoking the provisions of section 80- IA(10) read with section 10B(7), in the context of the Transfer Pricing Officer's order is unsustainable. The Tribunal has held that the Assessing Officer was not justified…

THE DCIT,(OSD)-1, CIRCLE-4,, AHMEDABAD vs. MIDVALLEY HEALTHCARE SERVICES PVT.LTD.,, AHMEDABAD

In the result, the CO of the assessee is partly allowed

ITA 204/AHD/2013[2008-09]Status: DisposedITAT Ahmedabad11 Mar 2021AY 2008-09

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

For Respondent: Shri Virendra Ojha, CIT. D.R

Section 10BSection 80ISection 92C

…submitted that the issue on hand is squarely covered by the decision of Chennai, Bangalore and Hyderabad ITAT in case of Visual Graphics Computing Services (India) Pvt Ltd vs. ACIT reported in 15 ITR (Trib) 393, Tweezerman (India) Pvt Ltd vs ACIT reported in 133 TTJ 308, Weston Knowledge System & Solution (India) Pvt Ltd vs. ITO reported in 52 SOT 120 (URO) and Digital Equipment India Ltd vs. DCIT reported in 103 TTJ 329. 5.2 The assessee further submitted that being a 100% EOU it has to file quarterly and annual reports of sales details with STPI in Software Export Declaration (SOFTEX) Form. After verifying and…

DEPUTY COMMISSIONER OF INCOME-TAX vs. M/S. HONEYWELL AUTOMATION INDIA LTD.,, PUNE

In the result, the appeal of Revenue is dismissed

ITA 619/PUN/2015[2003-04]Status: DisposedITAT Pune03 Mar 2020AY 2003-04

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

For Appellant: Shri Ajit Kumar JainFor Respondent: Shri T. Vijaya Bhaskar Reddy

Section 10ASection 10A(7)Section 251(2)

…f the Transfer Pricing Officer. In fact these issues have already been considered in various orders of the Tribunal. The Income-tax Appellate Tribunal, Chennai "A" Bench in the case of Tweezerman (India) P. Ltd. v. Addl. CIT [2010] 4 ITR (Trib) 130 (Chennai) (133 TTJ 308) has considered the matter in detail and held that the reduction of eligible profits of an assessee as done by the Assessing Officer by invoking the provisions of section 80-IA(10) read with section 10B(7), in the context of the Transfer Pricing Officer's order is unsustainable. The Tribunal has held that the Assessing Officer was not justified t…

M/S. HONEWELL AUTOMATION INDIA LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of Revenue is dismissed

ITA 583/PUN/2015[2003-04]Status: DisposedITAT Pune03 Mar 2020AY 2003-04

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

For Appellant: Shri Ajit Kumar JainFor Respondent: Shri T. Vijaya Bhaskar Reddy

Section 10ASection 10A(7)Section 251(2)

…f the Transfer Pricing Officer. In fact these issues have already been considered in various orders of the Tribunal. The Income-tax Appellate Tribunal, Chennai "A" Bench in the case of Tweezerman (India) P. Ltd. v. Addl. CIT [2010] 4 ITR (Trib) 130 (Chennai) (133 TTJ 308) has considered the matter in detail and held that the reduction of eligible profits of an assessee as done by the Assessing Officer by invoking the provisions of section 80-IA(10) read with section 10B(7), in the context of the Transfer Pricing Officer's order is unsustainable. The Tribunal has held that the Assessing Officer was not justified t…

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ANNAPURNA BUSINESS SOLUTIONS, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

ITA 869/HYD/2015[2010-11]Status: DisposedITAT Hyderabad17 Dec 2019AY 2010-11

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

For Appellant: Shri S.Rama Rao, ARFor Respondent: Shri Y.V.S.T.Sai, CIT-DR

Section 10ASection 132

…. M/s Annapurna Business Solutions, Hyderabad be said that only because average profit earned by comparables is 15%, the profit earned by assessee at 50% is not reasonable. The Chennai Bench of the Tribunal in case of Tweezmen India Pvt. Ltd., Vs. Addl. CIT, 133 TTJ 308 while considering similar issue held that the provisions of section 80IA(10) do not give arbitrary power to AO to fix the profits of assessee. AO has to specify as to why he feels that profits of assessee are being shown at higher figure. AO has to further show as to how he has computed ordinary profits which he deems to be profit which assessee…

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ANNAPURNA BUSINESS SOLUTIONS, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

ITA 868/HYD/2015[2009-10]Status: DisposedITAT Hyderabad17 Dec 2019AY 2009-10

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

For Appellant: Shri S.Rama Rao, ARFor Respondent: Shri Y.V.S.T.Sai, CIT-DR

Section 10ASection 132

…. M/s Annapurna Business Solutions, Hyderabad be said that only because average profit earned by comparables is 15%, the profit earned by assessee at 50% is not reasonable. The Chennai Bench of the Tribunal in case of Tweezmen India Pvt. Ltd., Vs. Addl. CIT, 133 TTJ 308 while considering similar issue held that the provisions of section 80IA(10) do not give arbitrary power to AO to fix the profits of assessee. AO has to specify as to why he feels that profits of assessee are being shown at higher figure. AO has to further show as to how he has computed ordinary profits which he deems to be profit which assessee…

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ANNAPURNA BUSINESS SOLUTIONS, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

ITA 867/HYD/2015[2008-09]Status: DisposedITAT Hyderabad17 Dec 2019AY 2008-09

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

For Appellant: Shri S.Rama Rao, ARFor Respondent: Shri Y.V.S.T.Sai, CIT-DR

Section 10ASection 132

…. M/s Annapurna Business Solutions, Hyderabad be said that only because average profit earned by comparables is 15%, the profit earned by assessee at 50% is not reasonable. The Chennai Bench of the Tribunal in case of Tweezmen India Pvt. Ltd., Vs. Addl. CIT, 133 TTJ 308 while considering similar issue held that the provisions of section 80IA(10) do not give arbitrary power to AO to fix the profits of assessee. AO has to specify as to why he feels that profits of assessee are being shown at higher figure. AO has to further show as to how he has computed ordinary profits which he deems to be profit which assessee…

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ANNAPURNA BUSINESS SOLUTIONS, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

ITA 866/HYD/2015[2007-08]Status: DisposedITAT Hyderabad17 Dec 2019AY 2007-08

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

For Appellant: Shri S.Rama Rao, ARFor Respondent: Shri Y.V.S.T.Sai, CIT-DR

Section 10ASection 132

…. M/s Annapurna Business Solutions, Hyderabad be said that only because average profit earned by comparables is 15%, the profit earned by assessee at 50% is not reasonable. The Chennai Bench of the Tribunal in case of Tweezmen India Pvt. Ltd., Vs. Addl. CIT, 133 TTJ 308 while considering similar issue held that the provisions of section 80IA(10) do not give arbitrary power to AO to fix the profits of assessee. AO has to specify as to why he feels that profits of assessee are being shown at higher figure. AO has to further show as to how he has computed ordinary profits which he deems to be profit which assessee…

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ANNAPURNA BUSINESS SOLUTIONS, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

ITA 865/HYD/2015[2006-07]Status: DisposedITAT Hyderabad17 Dec 2019AY 2006-07

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

For Appellant: Shri S.Rama Rao, ARFor Respondent: Shri Y.V.S.T.Sai, CIT-DR

Section 10ASection 132

…. M/s Annapurna Business Solutions, Hyderabad be said that only because average profit earned by comparables is 15%, the profit earned by assessee at 50% is not reasonable. The Chennai Bench of the Tribunal in case of Tweezmen India Pvt. Ltd., Vs. Addl. CIT, 133 TTJ 308 while considering similar issue held that the provisions of section 80IA(10) do not give arbitrary power to AO to fix the profits of assessee. AO has to specify as to why he feels that profits of assessee are being shown at higher figure. AO has to further show as to how he has computed ordinary profits which he deems to be profit which assessee…

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ANNAPURNA BUSINESS SOLUTIONS, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

ITA 864/HYD/2015[2005-06]Status: DisposedITAT Hyderabad17 Dec 2019AY 2005-06

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

For Appellant: Shri S.Rama Rao, ARFor Respondent: Shri Y.V.S.T.Sai, CIT-DR

Section 10ASection 132

…. M/s Annapurna Business Solutions, Hyderabad be said that only because average profit earned by comparables is 15%, the profit earned by assessee at 50% is not reasonable. The Chennai Bench of the Tribunal in case of Tweezmen India Pvt. Ltd., Vs. Addl. CIT, 133 TTJ 308 while considering similar issue held that the provisions of section 80IA(10) do not give arbitrary power to AO to fix the profits of assessee. AO has to specify as to why he feels that profits of assessee are being shown at higher figure. AO has to further show as to how he has computed ordinary profits which he deems to be profit which assessee…

ANNAPURNA BUSINESS SOLUTIONS, HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

ITA 836/HYD/2015[2010-11]Status: DisposedITAT Hyderabad17 Dec 2019AY 2010-11

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

For Appellant: Shri S.Rama Rao, ARFor Respondent: Shri Y.V.S.T.Sai, CIT-DR

Section 10ASection 132

…. M/s Annapurna Business Solutions, Hyderabad be said that only because average profit earned by comparables is 15%, the profit earned by assessee at 50% is not reasonable. The Chennai Bench of the Tribunal in case of Tweezmen India Pvt. Ltd., Vs. Addl. CIT, 133 TTJ 308 while considering similar issue held that the provisions of section 80IA(10) do not give arbitrary power to AO to fix the profits of assessee. AO has to specify as to why he feels that profits of assessee are being shown at higher figure. AO has to further show as to how he has computed ordinary profits which he deems to be profit which assessee…

ANNAPURNA BUSINESS SOLUTIONS, HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

ITA 835/HYD/2015[2009-10]Status: DisposedITAT Hyderabad17 Dec 2019AY 2009-10

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

For Appellant: Shri S.Rama Rao, ARFor Respondent: Shri Y.V.S.T.Sai, CIT-DR

Section 10ASection 132

…. M/s Annapurna Business Solutions, Hyderabad be said that only because average profit earned by comparables is 15%, the profit earned by assessee at 50% is not reasonable. The Chennai Bench of the Tribunal in case of Tweezmen India Pvt. Ltd., Vs. Addl. CIT, 133 TTJ 308 while considering similar issue held that the provisions of section 80IA(10) do not give arbitrary power to AO to fix the profits of assessee. AO has to specify as to why he feels that profits of assessee are being shown at higher figure. AO has to further show as to how he has computed ordinary profits which he deems to be profit which assessee…

ANNAPURNA BUSINESS SOLUTIONS, HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

In the result appeals of the revenue are partly allowed and the appeals of the assessee are allowed

ITA 834/HYD/2015[2008-09]Status: DisposedITAT Hyderabad17 Dec 2019AY 2008-09

Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent

For Appellant: Shri S.Rama Rao, ARFor Respondent: Shri Y.V.S.T.Sai, CIT-DR

Section 10ASection 132

…. M/s Annapurna Business Solutions, Hyderabad be said that only because average profit earned by comparables is 15%, the profit earned by assessee at 50% is not reasonable. The Chennai Bench of the Tribunal in case of Tweezmen India Pvt. Ltd., Vs. Addl. CIT, 133 TTJ 308 while considering similar issue held that the provisions of section 80IA(10) do not give arbitrary power to AO to fix the profits of assessee. AO has to specify as to why he feels that profits of assessee are being shown at higher figure. AO has to further show as to how he has computed ordinary profits which he deems to be profit which assessee…

Tweezerman (India) P. Ltd. v. Addl. CIT

What is Tweezerman (India) P. Ltd. v. Addl. CIT authority for?

Also referred to as

Also reported as

Judgments citing Tweezerman (India) P. Ltd. v. Addl. CIT

EATON TECHNOLOGIES PVT.LTD,,PUNE vs. PR. COMMISSIONER OF INCOME-TAX-1,, PUNE

EATON TECHNOLOGIES PVT.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(2),, PUNE

DEPUTY COMMISSIONER OF INCOME TAX CIR 1(1), PUNE vs. EATON TECHNOLOGIES PVT. LTD.,, PUNE

DEPUTY COMMISSIONER OF INCOME TAX CIR 1(1), PUNE vs. EATON TECHNOLOGIES PVT. LTD.,, PUNE

DEPUTY COMMISSIONER OF INCOME TAX, PUNE vs. HALLIBURTON TECHNOLOGY INDIA PVT. LTD, PUNE

EATON TECHNOLOGIES PVT.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(2),, PUNE

DEPUTY COMMISSIONER OF INCOME-TAX vs. M/S. HONEYWELL AUTOMATION INDIA LTD.,, PUNE

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DEPUTY COMMISSIONER OF INCOME-TAX vs. M/S. HONEYWELL AUTOMATION INDIA LTD.,, PUNE

M/S. HONEWELL AUTOMATION INDIA LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

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DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ANNAPURNA BUSINESS SOLUTIONS, HYD, HYDERABAD

DCIT, CENTRAL CIRCLE-2(1), HYD, HYDERABAD vs. ANNAPURNA BUSINESS SOLUTIONS, HYD, HYDERABAD

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ANNAPURNA BUSINESS SOLUTIONS, HYD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD