M/S.FILTREX TECHNOLOGIES PRIVATE LTD.,,BANGALORE vs. ASST. COMMISSIONER OF INCOME TAX, BANGALORE
In the result, appeal by the Assessee is treated as allowed for statistical purpose
ITA 469/BANG/2017[2012-13]Status: DisposedITAT Bangalore11 Apr 2018AY 2012-13
Bench: Shri N.V Vasudevan & Shri Jason P Boazit(Tp)A Nos.469/Bang/2017 (Asst. Year – 2012-13) M/S Filtrex Technologies Pvt. Ltd., #36/4, Raghavendra Nagar, Near Ring Road, 4Th Cross, Hrbr Layout, Bangalore. Pan – Aaacf4091P. …..Appellant Vs. The Asst. Commissioner Of Income-Tax, Circle-(3)(1), Bengaluru. …. Respondent Appellant By : Shri Padmchand Khincha, C.A Respondent By : Shri C.H Sundar Rao, Cit(Dr) Date Of Hearing : 08-03-2018 Date Of Pronouncement : 11-04-2018 O R D E R
For Appellant: Shri Padmchand Khincha, C.AFor Respondent: Shri C.H Sundar Rao, CIT(DR)
Section 143(3)Section 92
transfer pricing analysis.
The basis for the costs incurred, the activities for which they were
IT(TP)ANo.469/B/17
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incurred, and the benefit accruing to the Taxpayer from those activities must all be proved to determine first, whether, and how much, of such expenditure was for the purpose of benefit of the Taxpayer, and secondly, whether that amount meets