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
Transfer Pricing
in respect of International Transactions” by
TPO relied upon the decision in assessee’s own
case for Assessment Year 2007-08 and 2008-09?
3
(v)
Whether on the facts and circumstances of the
case and on law Learned Income Tax Appellate
Tribunal was justified in granting relief to
the assessee on addition of ₹34
