112 results for “transfer pricing”+ Section 36(1)(vi)clear
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In the result, the appeal of the assessee is allowed
Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)
vi). Hon'ble Rajasthan High Court in the case of Commissioner of Income- Tax vs Emery Stone Manufacturing Company (213 ITR 843) has held as under: "Simply because the facts have been disclosed by the assessee, it does not give immunity from revisional jurisdiction which the Commissioner can exercise u/s 263 and as such even in a case where