M/S UB SPORTS MANAGEMENT OVERSEAS LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX(INTERNATIONAL TAXATION) CIRCLE-1(2), BANGALORE

In the result, the appeals filed by the assessees are partly allowed

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

92F(ii) means a price which is applied or proposed to be applied in a transaction between persons other than associated in a uncontrolled conditions. As per section 92C(1), the arms length price in relation to an international transaction shall be determined by any of the six methods prescribed therein. As mentioned earlier in the present case, the assessee

TE CONNECTIVITY INDIA PRIVATE LIMITED,BANGALORE vs. THE OFFICE OF THE DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 7(1)(1), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K

gain on defined employee benefit plan as an operating item and recompute the PLI of the assessee for the relevant segments. The ground raised by the assessee on this issue is allowed 17.6 The interconnected issue raised by the assessee through Ground Nos. 4, 7, 8 & 9 of the appeal are interconnected and pertains to inclusion of certain comparable companies

M/S. TECHNICOLOR INDIA PVT. LTD.,,GURGAON vs. DCIT, NEW DELHI

Bench: Shri George George K & Shri Laxmi Prasad Sahuassessment Year : 2010-11

92F of the Act. 11. That on the facts and the circumstances of the case and in law, the AO/ DRP / TPO have erred in not considering foreign exchange fluctuation gain I loss while computing the operating margins. 12. That on the facts and the circumstances of the case and in law, the AO/DRP/ TPO have erred in not providing