“international transaction”

Transfer PricingSection 92BSection 92B3,408 judgments

The decision most relied on for international transaction is Sony Ericsson Mobile Communications India Pvt. Ltd. v. CIT (374 ITR 118), cited in 499 judgments on BharatTax.

Leading authorities on international transaction

Sony Ericsson Mobile Communications India Pvt. Ltd. v. CIT

374 ITR 118 · 2015 · High Court

499

citing judgments

The existence of an international transaction for Advertising and Marketing Promotion (AMP) expenditure requires the revenue to discharge the burden of proof. An explanation inserted under Section 92B does not automatically make AMP expenditure an international transaction.

CIT v. EKL Appliances Ltd.

345 ITR 241 · 2012 · High Court

422

citing judgments

Transfer pricing adjustments for outstanding receivables are permissible only if the Tax Officer establishes, through analysis over a period, a pattern indicating an international transaction intended to benefit an associated enterprise. The Tax Officer cannot question purely business decisions like royalty payments or exceed jurisdiction by applying cost-benefit analysis to determine the arm's length price of services.

India Vs. Azadi Bachao Andolan 263 ITR 706 (SC); and Vodafone International Holdings B.V v. Union of India

341 ITR 1 · 2012 · Supreme Court

295

citing judgments

Legitimate tax planning is permissible, allowing taxpayers to arrange their affairs to minimize tax liabilities while respecting the "look at test" for transaction genuineness and the separate entity principle in corporate taxation. The source of funds for treaty-beneficial structures does not automatically invalidate the transaction.

Maruti Suzuki India Ltd. v. CIT

381 ITR 117 · 2016 · High Court

220

citing judgments

The Bright Line Test (BLT) is not a recognized method under the Income-tax Act and Rules for benchmarking advertising, marketing, and promotion (AMP) expenses or for determining the existence of an international transaction or its Arm's Length Price. The Revenue must first establish the existence and price of an international transaction before seeking an ALP adjustment.

Vodafone India Services (P.) Ltd. v. Union of India

368 ITR 1 · 2014 · High Court

172

citing judgments

The issue of shares and share premium is a capital account transaction, not an income-generating event, therefore Chapter X (Transfer Pricing) provisions are not attracted to deem notional or hypothetical income from such transactions.

Sir Kikabhai Premchand v. CIT

24 ITR 506 · 1953 · Supreme Court

156

citing judgments

One cannot make a taxable profit or loss from transactions with oneself, as profit only arises from dealings with external third parties, even when transferring assets between different accounts or divisions of the same entity.

PCIT v. Redington (India) Ltd.

430 ITR 298 · 2021 · High Court

132

citing judgments

A corporate guarantee issued to Associated Enterprises (AEs) is an international transaction under Section 92B, requiring adjustments for guarantee commission due to inherent risk. The reasonable arm's length rate for benchmarking such corporate guarantees can be determined using internal or external comparable uncontrolled prices.

Bausch & Lomb Eye Care (India) Pvt. Ltd. v. Additional CIT

381 ITR 227 · 2016 · High Court

127

citing judgments

The existence of an international transaction must be established before its arm's length price can be determined. An alleged 'excessive' AMP expenditure cannot unilaterally expand the scope of an international transaction if its existence is contested.

Judgments citing international transaction

Ipca Laboratories Ltd, Mumbai vs. ACIT (Ltu), Mumbai

In the result, appeal filed by the learned assessing officer is dismissed

ITA 8120/MUM/2010[2005-06]Status: DisposedITAT Mumbai29 Aug 2022AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR

Section 801BSection 801CSection 80ISection 92C

cost of employee’s stock option scheme. The return of the assessee was picked up for scrutiny. As assessee has entered into the international transaction of purchase of pharmaceutical products of ₹201.14 lacs, sales of pharmaceuticals products of ₹4,328.53 lacs, unsecured loan advanced to AEs without charging interest ... learned Addl. Commissioner of Income Tax, TPO (1)(3), Mumbai (the learned Transfer Pricing Officer) for computation of Arms Length Price of above international transactions as shown in form no.3CEB. The assessee benchmarked the purchase and sale of pharmaceuticals products adopting Comparable Uncontrolled Price [CUP] method. The learned Transfer Pricing

Ipca Laboratories Ltd, Mumbai vs. DCIT (Ltu), Mumbai

In the result, appeal filed by the learned assessing officer is dismissed

ITA 8084/MUM/2010[2006-07]Status: DisposedITAT Mumbai29 Aug 2022AY 2006-07

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR

Section 801BSection 801CSection 80ISection 92C

ACIT Cen Cir 13, Mumbai vs. Ipca Laboratories Ltd, Mumbai

In the result, appeal filed by the learned assessing officer is dismissed

ITA 7511/MUM/2010[2005-06]Status: DisposedITAT Mumbai29 Aug 2022AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR

Section 801BSection 801CSection 80ISection 92C

M/S Edelweiss Rural & Corporate Services Private Limited, Mumbai vs. JCIT Central Circle-1(2), Mumbai

In the result, appeal of the assessee for A

ITA 1041/MUM/2022[2015-16]Status: DisposedITAT Mumbai26 Aug 2022AY 2015-16

Section 127(2)Section 133ASection 143(1)Section 143(3)Section 147

made by the ld. AO to the ld. Transfer Pricing Officer (ld. TPO) for determining the arm‟s length price in respect of international transaction carried out by the assessee. The ld. TPO passed an order u/s.92CA(3) of the Act dated 31/01/2020 for A.Y.2015-16 wherein he made transfer pricing

M/S Edelweiss Rural & Corporate Services Private Limited (Earlier Know As M/S Edelweiss Commodities Services Limited), Mumbai vs. ACIT Central Circle-1(2), Mumbai

In the result, appeal of the assessee for A

ITA 1040/MUM/2022[2012-13]Status: DisposedITAT Mumbai26 Aug 2022AY 2012-13

Section 127(2)Section 133ASection 143(1)Section 143(3)Section 147

DCIT Cent -Cir.1(2), Mumbai vs. M/S. Sunny Vista Realtors Pvt. Ltd, Mumbai

In the result appeal of the learned AO is allowed

ITA 1711/MUM/2021[2015-16]Status: DisposedITAT Mumbai26 Aug 2022AY 2015-16

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm The Dy. Commissioner Of Income M/S Sunny Vista Realtors Pvt. Tax, Ltd. Central Circle-1(2), 511, Dalamal Towers, 211, 906, 9Th Floor, Pratishta Bhavan, Vs. Nariman Point, Old Cgo Bldg. (Annexe), Mumbai-400 021 M.K. Road, Mumbai-400 020 (Respondent) (Appellant) Pan No. Aakcs1269E Assessee By : Ms. Kinjal Bhuta, Nihar Mehta & Jayesh B. Kapani, Cas’ Revenue By : Dr. Pallavi Darade, Cit Dr Date Of Hearing: 30.05.2022 Date Of Pronouncement : 26.08.2022

For Appellant: Ms. Kinjal BhutaFor Respondent: Dr. Pallavi Darade, CIT DR

Section 143(3)

under: Mr. Sunny Nista Realtors P Ltd.; A.Y. 18-19 Difference in depreciation in block (14651234) fixed assets as per international transaction Act, 1961 Provision for doubtful advances 20294937 Unabsorbed business loss 254687910 Unabsorbed depreciation 20548185 Deferred tax assets 280879798 Deferred tax assets recognized in the 270000000 financial statements

M/S Honeywell Technology Solutions Lab Private Limited, Bangalore vs. Joint Commissioner of Income Tax Special Range-3, Bangalore

ITA 2889/BANG/2018[2012-13]Status: DisposedITAT Bangalore26 Aug 2022AY 2012-13

Bench: Shri N.V. Vasudevan & Shri Laxmi Prasad Sahuassessment Year : 2012-13

For Appellant: Smt. Shreya Loyalaka, AdvocateFor Respondent: Shri Sumer Singh Meena, CIT (DR)

Section 201(1)Section 40Section 80J

with the Rules, and conducting a fresh economic analysis for the determination of the arm's length price ("ALP") in connection with the impugned international transaction and holding that the Appellant's international transaction relating to provision of ITeS is not at arm's length. 21. The learned ... income of Rs.213.50 crores. The case was selected for scrutiny. During the course of assessment proceedings, the AO observed that the assessee has taken international transactions accordingly reference u/s 92CA was made by the DICT, Circle-14 and accordingly the approval was obtained from CIT, Bengaluru – 1. During the course

Textron India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Bangalore

In the result, the appeal filed by the assessee stands allowed on the grounds argued by assessee and other issues that has not been pressed is kept open

ITA 711/BANG/2017[2012-13]Status: DisposedITAT Bangalore26 Aug 2022AY 2012-13

For Appellant: Shri Sumit Khurana, CAFor Respondent: Shri V.S. Chakrapani, CIT-DR

Section 92C(3)(c)Section 92D

reported in [2019] 105 taxmann.com 40 (Bombay). 9. We note that, the Ld.TPO considered both AE and non-AE transaction together for benchmarking the international transaction, and therefore respectfully following the observations of Hon’ble Bombay High Court in case of PCIT vs. J.P. Morgan Services India (P.) Ltd. (supra ... working capital differences. On this issue we have heard the rival submisSions. The relevant provisions of the Act in so far as comparability of international transaction with a transaction of similar nature entered into between unrelated parties, provides as follows: Determination of arm's length price under section 92C . Page

Asstt CIT - 5(1)(1), Mumbai vs. M/S. General Atlantic P. Ltd, Mumbai

In the result appeal filed by the revenue is dismissed

ITA 1270/MUM/2021[2010-11]Status: DisposedITAT Mumbai25 Aug 2022AY 2010-11

Bench: Shri Amit Shukla & Shri Gagan Goyalacit-5(1)(1), Room No. 568, 5Th Floor, Aayakar Bhavan, M.K. Road, Mumbai- 400020. ...... Appellant Vs. M/S General Atlantic Pvt. Ltd., Level 19, Birla Auror, Dr. Annie Besant Road, Worli, Mumbai- 400030. Pan: Aabcg7917Q ..... Respondent Appellant By : Dr. Yogesh Kamat, Cit-Dr Respondent By : Sh. Porus Kaka/Divesh Chawla Date Of Hearing : 30/05/2022 Date Of Pronouncement : 25/08/2022 Order Per Gagan Goyal, A.M:

For Appellant: Dr. Yogesh Kamat, CIT-DRFor Respondent: Sh. Porus Kaka/Divesh Chawla

Section 133(6)

risk basis. While rendering these services, the assessee is remunerated on full cost + mark-up basis of 18%. The value of the international transactions entered into by the assessee with its AE for the year under consideration amounts to Rs. 59,03,07,520/-. During the year under consideration

Ness Technologies (India) P. Ltd., Navi Mumbai vs. The Addl/Jt/Asstt, /ITO, Nationa E-Assessment Centre, Delhi

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

ITA 1084/MUM/2021[2016-17]Status: DisposedITAT Mumbai25 Aug 2022AY 2016-17

Bench: Shri B. R. Baskaran, Am & Shri Aby T. Varkey, Jm आयकर अपील सं/ I.T.A. No.1084/Mum/2021 (निर्धारण वर्ा / Assessment Years: 2016-17) Ness Digital Engineering बिधम/ The (India) Pvt. Ltd. Addl/Jt./Dy./Acit/Ito, Vs. (Formerly Known As Ness National E-Assessment Technologies (India) Pvt. Centre, Delhi. Ltd. Unit No. 201, 2Nd Office Floor, Building No. 5 & 6, Mindspace Sez, Thane Belapur Road, Airoli, Navi Mumbai-400708. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaaca9649L (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Devendra Jain Revenue By: Shri Samual Pitta (Dr) सुनवाई की तारीख / Date Of Hearing: 03/08/2022 घोषणा की तारीख /Date Of Pronouncement: 25/08/2022 आदेश / O R D E R Per Aby T. Varkey, Jm: This Is An Appeal Preferred By The Assessee Against The Order By The Assessing Officer (Ao)/(National E- Assessment Central. Delhi) Dated 19.04.2021 For The Assessment Year 2016-17 Passed U/S 143(3) R.W.S. 144C(13) Read With Section 144B Of The Income Tax Act, 1961 (Hereinafter “The Act”). 2. At The Outset, The Ld. Ar Of The Assessee Brought To Our Notice That The Sole Issue (Even Though The Assessee Has Raised Ground Nos. 1 To 8) Is Against The Action Of The Ao/Drp In Confirming The Transfer Pricing Adjustment (Tpa) Of Rs.73,69,403/- In Relation To International Transactions Of Reimbursement Of Expenses Received By The Assessee Company From Its Associate Enterprises (Ae).

For Appellant: Shri Devendra JainFor Respondent: Shri Samual Pitta (DR)

Section 115JSection 143(3)Section 144BSection 92C

against the action of the AO/DRP in confirming the Transfer Pricing Adjustment (TPA) of Rs.73,69,403/- in relation to International Transactions of reimbursement of expenses received by the assessee company from its Associate Enterprises (AE). 2 A.Y. 2016-17 Ness Technologies India Pvt. Ltd. 3. Brief facts is that ... provisions u/s 115JB of the Act. Later, the case was selected for scrutiny and the AO taking note that the assessee had international transaction reported in the Form 3CEB referred the same u/s 92CA(1) to the TPO for determination of Arm’s Length Price (ALP) who noted the fact

DCIT, Cir-6(2)(2), Mumbai vs. Diageo India Pvt.Ltd., Mumbai

In the result, appeal filed by the assessee is partly allowed

ITA 2858/MUM/2016[2011-12]Status: DisposedITAT Mumbai25 Aug 2022AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Diageo India P. Ltd. Dcit 4Th Floor, Nicholas Piramal Tower Rg 6(2)(2) Peninsula Corporate Park, Aayakar Bhavan, Vs. Ganpatrao Kadam Marg, Mk Road, Lower Parel, Mumbai-400 020 Mumbai-400 013 (Appellant) (Respondent) Pan No. Aaaci 3378 L Diageo India P. Ltd. Dcit 4Th Floor, Nicholas Piramal Tower Rg 6(2)(2) Peninsula Corporate Park, Aayakar Bhavan, Vs. Ganpatrao Kadam Marg, Mk Road, Lower Parel, Mumbai-400 020 Mumbai-400 013 (Appellant) (Respondent)

For Appellant: Shri Nishant Thakkar &For Respondent: Ms. Vatsalaa Jha, CIT DR

Section 143(3)Section 144C(13)Section 253Section 92BSection 92C

extent of Rs. 35,82,41,000/- by holding that the Assessee provides brand promotion services to its overseas associated enterprises. Not an international transaction 3. erred in holding that the AMP expenditure incurred by the Assessee is an international transaction as per provisions of Section ... Pemod Ricard India Private Limited +/-5 percent benefit 11. Benefit given as per section 92C of the Act for adjustment of +/- 5% to international transactions, if the same is within the range, should be allowed. 12. without prejudice to the above, erred in computing transfer pricing adjustment on total transactions

Diageo India P.Ltd, Mumbai vs. DCIT RG 6(2)(2), Mumbai

In the result, appeal filed by the assessee is partly allowed

ITA 1002/MUM/2016[2011-12]Status: DisposedITAT Mumbai25 Aug 2022AY 2011-12

For Appellant: Shri Nishant Thakkar &For Respondent: Ms. Vatsalaa Jha, CIT DR

Section 143(3)Section 144C(13)Section 253Section 92BSection 92C

Atos It Services Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle-1(1)(1), Bangalore

In the result, the appeal by the assessee is partly allowed

ITA 226/BANG/2021[2016-17]Status: DisposedITAT Bangalore25 Aug 2022AY 2016-17

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri Dhanesh Bafna, CAFor Respondent: Shri Bijoy Kumar Panda, CIT(DR)(ITAT), Bengaluru

Section 143(2)Section 143(3)Section 92B(2)Section 92C

selected for scrutiny through CASS and notice u/s. 143(2) of the Act was duly served on the assessee. Since the assessee had international transactions with its AE, the matter was referred to the Transfer Pricing Officer (TPO) in order to determine the Arms Length Price (ALP) of the international ... Aggrieved, the assessee is in appeal before the Tribunal. Transfer Pricing adjustment 5. During the year under consideration, the assessee had the following international transactions:- Description Amount (INR) Provision of Software Development Service 1,893,755,572 Payment for receipt of intra-group services 22,632,176 Deemed international transaction

Citrix R & D India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle- 2(1)(1), Bangalore

In the result, the appeal filed by the assessee stands allowed partly as indicated herein above

ITA 220/BANG/2021[2016-17`]Status: DisposedITAT Bangalore25 Aug 2022

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 220/Bang/2021 Assessment Year : 2016-17 M/S. Citrix R&D India Pvt. Ltd., The Deputy Prestige Dynasty, Commissioner Of Ground Floor, Income Tax, 33/2, Ulsoor Road, Circle – 2(1)(1), Bangalore – 560042. Vs. Bangalore. Pan: Aabcn3639C Appellant Respondent Assessee By : Shri Sumit Khurana, Ca Revenue By : Shri M. Mathivanan, Cit-Dr Date Of Hearing : 04-07-2022 Date Of Pronouncement : 25-08-2022 Order Per Beena Pillaipresent Appeal By The Assessee Has Been Filed By Assessee Against The Assessment Order Dated 30/03/2021 Passed By The National E-Assessment Centre, Delhi Relating To Assessment Year 2016-17 On Following Grounds Of Appeal: “The Grounds Mentioned Herein By The Appellant Are Without Prejudice To One Another. 1. That The Order Passed By The Learned Ao To The Extent Prejudicial To The Appellant, Is Bad In Law & Liable To Be Quashed. Transfer Pricing - 2. That The National E-Assessment Centre, Delhi / Deputy Commissioner Of Income Tax, Circle 2(1)(1), Bangalore ("Assessing Officer" Or "Learned Ao") & The Dispute Resolution Panel - 1 ("Learned Panel" Or "Learned Drp")

For Appellant: Shri Sumit Khurana, CAFor Respondent: Shri M. Mathivanan, CIT-DR

were issued and served on the assessee. 2.2 The Ld.AO noted that, during the F.Y. 2015-16, the assessee company had international transactions as per Section 92 of the Income-tax Act, 1961. According to Section 92CA of the Income- tax Act, 1961, the case was referred to the Transfer ... Pricing Officer in order to determine the Arm's Length Price after obtaining necessary approval. The Ld.TPO observed that the assessee had following international transaction with its AE for the year under consideration: Sl. Particulars Amount (in INR) No 1. Provision for software 353,73,66,567 development services

M/S Infineon Technologies India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-3(1)(1), Bangalore

ITA 3355/BANG/2018[2014-15]Status: DisposedITAT Bangalore25 Aug 2022AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 3355/Bang/2018 Assessment Year : 2014-15 M/S. Infineon Technologies India Pvt. The Deputy Ltd., Commissioner Of 9Th Floor, Prestige Income Tax, Thirulakshmi, Circle – 3(1)(1), No. 11, Mg Road, Vs. Bangalore. Bangalore. Pan: Aabcs6967N Appellant Respondent : Shri K.R. Vasudevan, Assessee By Advocate : Shri Sumer Singh Meena, Revenue By Cit Dr Date Of Hearing : 12-07-2022 Date Of Pronouncement : 25-08-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against Assessment Order Dated 26/10/2018 By The Ld.Dcit, Circle – 3(1)(1), Bangalore On Following Grounds Of Appeal: “A. Transfer Pricing The Grounds Mentioned Hereinafter Are Without Prejudice To One Another. 1. The Learned Assessing Officer ('Learned Ao'), Learned Transfer Pricing Officer ('Learned Tpo') & The Honourable Dispute Resolution Panel ('Hon'Ble Drp') Grossly Erred In Adjusting The Transfer Price By Inr 9,56,93,721/- With Respect To The International

For Respondent: Shri K.R. Vasudevan

Section 92C

conducting a fresh comparability analysis by introducing various filters for the purpose of determining the Arm's Length Price ('ALP') of the international transaction. 4. The learned AO/ learned TPO/ Hon'ble DRP erred in not considering the previous two years financial data of the comparable companies while determining ... OUTSTANDING RECEIVABLES 18. The learned AO/ learned TPO/ Hon'ble DRP erred in not considering the fact that receivables cannot be considered as an international transaction as it does not fall within the purview of capital financing as stated by Sec. 92B of the Act. Page

M/S Praxair India Pvt Ltd, Bangalore vs. Deputy Commissioner of Income Tax Ltpu Circle-1, Bangalore

In the result, the appeal filed by the assessee is partly allowed

ITA 2839/BANG/2017[2013-14]Status: DisposedITAT Bangalore25 Aug 2022AY 2013-14

For Appellant: Sri.T.Suryanarayana, Senior AdvocateFor Respondent: Sri.Bijoy Kumar Panda, CIT-DR

Section 143(2)Section 143(3)Section 14ASection 37

course of assessment proceedings, it was noticed that the 2 IT(TP)A No.2839/Bang/2017. M/s.Praxair India Private Limited. assessee had entered into several international transactions with its Associate Enterprises (AEs). The international transactions entered by the assessee with its AEs exceeded Rs.15 crore. The assessee had made payment of royalty ... length. 3. The Assessing Officer referred the matter to the Transfer Pricing Officer (TPO) to determine the ALP of the said international transactions. The TPO vide order dated 25.10.2016 determined the TP adjustment in respect of international transaction of payment of royalty, payment towards technical and support services and payment

Mizuho Bank Ltd, Mumbai vs. DCIT (It) 3(2)(2), Mumbai

ITA 2786/MUM/2017[2011-12]Status: DisposedITAT Mumbai24 Aug 2022AY 2011-12

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri Madhur AgarwalFor Respondent: Shri K.C. Selvamani

Section 250Section 40Section 92C

counter guarantee by reputed international Banks, without adjudicating as to how the rate applied by the TPO is not comparable with the relevant international transaction. 8. Whether in the facts and circumstances of the case and in law, the Ld. CIT(A) was correct in directing to re-compute ... branch received Rs. 78.09 lakhs as commission. During the course of transfer pricing assessment proceedings, assessee was asked to furnish complete details regarding this international transaction. In reply, assessee submitted that the commission was received for furnishing the bank guarantees to the Indian customers at the request of the head

Mizuho Bank Ltd, Mumbai vs. DDIT (It) 4(1), Mumbai

ITA 2785/MUM/2017[2010-11]Status: DisposedITAT Mumbai24 Aug 2022AY 2010-11

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri Madhur AgarwalFor Respondent: Shri K.C. Selvamani

Section 250Section 40Section 92C

DCIT (It) 3(2)(2), Mumbai vs. Mizuho Corporate Bank Maker, Mumbai

ITA 2712/MUM/2017[2011-12]Status: DisposedITAT Mumbai24 Aug 2022AY 2011-12

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri Madhur AgarwalFor Respondent: Shri K.C. Selvamani

Section 250Section 40Section 92C

DCIT (It) 3(2)(2), Mumbai vs. Mizuho Corporate Bank Maker, Mumbai

ITA 2711/MUM/2017[2010-11]Status: DisposedITAT Mumbai24 Aug 2022AY 2010-11

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri Madhur AgarwalFor Respondent: Shri K.C. Selvamani

Section 250Section 40Section 92C