2 results for “transfer pricing”+ Section 133(6)clear
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In the result, the additional ground of the appeal of the assessee is allowed
Bench: Shri.Vijay Pal Raoassessment Year: 2012-13 Sri Girdhar Gopal Rastogi, V. Commissioner Of Income Tax Dhundi Katra, Mirzapur, U.P. (Appeal), Allahabad Pan-Aanpr8525N (Appellant) (Respondent) Appellant By: Mr. R.N. Yadav, Adv & Mr. R.K. Kalyani, C.A. Respondent By: Mr. A.K. Singh, Sr. Dr Date Of Hearing: 26.04.2022 Date Of Pronouncement: 13.05.2022
6 Girdhar Gopal Rastogi Authorities under section 133A(3) and section 132(4) of the Act are not radically different. Under section 133A the statement is recorded by the authority whereas under section 132(4), the authority may examine such person on oath therefore, the statement recorded under section 133A has an evidentiary value. The decision relied upon