112 results for “transfer pricing”+ Carry Forward of Lossesclear
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In the result, all the appeals filed by the assessee are partly allowed for statistical purposes and the appeal filed by the Revenue is dismissed
Bench: Shri George George Kand Shri S.R. Raghunathait(Tp)A. Nos.:105, 106, 107/Chny/2024 & Ita No.3113/Chny/2024 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2013-14 & 2014-15 M/S. E.I.D. Parry India Ltd., The Deputy Commissioner Of No. 234, Dare House, Nsc Vs. Income Tax, Bose Road, Parrys Corner, Large Taxpayer Unit -1, Chennai 600 001. Chennai. [Pan: Aaace-0702-C] (अपीलाथ"/Appellant) (""यथ"/Respondent)
transfer pricing proceedings, the assessee has submitted that Letter of Comfort is a facility to avail credit by Parry America Inc. which is a subsidiary of the assessee company. Therefore, the assessee contented before the TPO that, the above facility is not a guarantee and the adjustment towards guarantee commission would not arise with reference to Section