JOSHI TECHNOLOGIES INTERNATIONAL INC INDIA PROJECTS,AHMEDABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE(INT.TAXN.)-1, AHMEDABAD

In the result, all the three appeals filed by the assessee are partly allowed

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 80, 81 & 244/Ahd/2022 (Assessment Years 2017-18, 2018-19 & 2019-20)

44C of the Act. The said expenses incurred amounting to Rs. 35,19,439/- (i.e. 1% of total contract costs as per para 2.6 of Section 2 of Appendix C to the PSC). Thus, in light of the above, the Ld. AR submitted that it is clear that even though amount of Rs. 5.55 Crore was reported

SUN PHARMACEUTICALS INDUSTRIES LTD. ( ERSTWHILE RANBAXY LABORATORIES LIMITED),BARODA vs. THE ACIT,CENT.CIRCLE-1, BARODA

68 taxmann.com 322, held that AE’s are accepted as tested party being the least complex for comparability analysis of international transaction of the assessee. The relevant extract of the order is reproduced as under: “18. We have carefully considered the rival contentions. We have also perused the relevant paragraphs of the several documents relied upon before