PRINCIPAL COMMISSIONER OF INCOME TAX-1 KOLKATA vs. M/S LANDIS GYR
In the result, the substantial questions of law (i)
ITAT/10/2021HC Calcutta03 Apr 2023
Bench: : The Hon’Ble Acting Chief Justice T.S. Sivagnanam & The Hon’Ble Justice Hiranmay Bhattacharyya Date : 3Rd April, 2023 Appearance : Mr. Soumen Bhattacharjee, Adv. ...For The Appellant Mr. Asim Choudhury, Adv. Mr. Soham Sen, Adv. ...For The Respondent. The Court : This Appeal Filed By The Revenue Under Section 260A Of The Income Tax Act, 1961 (The ‘Act’ For Brevity) Is Directed Against The Order Dated October 17, 2018 Passed By The Income Tax Appellate Tribunal, “C” Bench, Kolkata (The Tribunal) In Ita No.524/Kol/2017 For The Assessment Year 2012-13. The Revenue Has Raised The Following Substantial Questions Of Law For Consideration:
Section 260ASection 32Section 92C
Price
when
the
provision of Section 92C of the Income Tax Act,
1961, and read with rule 10B & Rule 10C of the
Income Tax Rules, 1962, allows for “Reliable
and
accurate
adjustment”
to
account
for
difference between intonated transaction and
comparable uncontrolled transactions ?
(ii) Whether
the
Learned
Income
Tax
Appellate
Tribunal
erred
in
law
in
allowing
the
depreciation on Intellectual
