SARASWATI AGRO CHEMICALS (INDIA) PVT. LTD,MOHALI vs. DCIT, CIRCLE-6(1), MOHALI
In the result, the transfer pricing adjustment so made by the AO and confirmed by the ld CIT(A) amounting to Rs 89,22,420/- is hereby set-aside and the ground of appeal is allowed
ITA 165/CHANDI/2024[2014-15]Status: DisposedITAT Chandigarh15 Oct 2024AY 2014-15
Bench: Or At The Time Of Hearing.”
For Appellant: Shri R.K. Gupta, C.A and Shri Akshun Gupta, C.AFor Respondent: Shri Vivek Vardhan, JCIT, Sr. DR
Section 143(1)Section 143(2)Section 143(3)Section 92BSection 92C
transfer pricing provisions. Similarly divided paid is not an item of expense but appropriation of profits. Thus, dividends are not subject to arm's length pricing principles. Hence Ld. TPO, Ld. A.O & Worthy CIT(A) are not justified to hold that once these items are reported in Form 3CEB as specified Domestic Transactions being any expenditure in respect of which