ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY, TRICHY vs. KUMARASAMY RAMAKRISHNAN, KARUR

In the result, all the three appeals filed by the Revenue are\nOrder pronounced in the court on 05th June, 2025 at Chennai

price whichever is lower. The appellant\ncontended that the stand of the AO is not correct also the statement recorded\nduring the survey has no evidentiary value. The appellant also submitted that\nthis component of stock difference does not represent the value of any\nexcess quantity of stock found during the course of survey in relation to the\nstock register

INLOGIC TECHNOLOGIES PRIVATE LIMITED,CHENNAI vs. DCIT CORP. CIRCLE 1(1) , CHENNAI

In the result, the appeal of the Assessee is partly allowed for statistical purposes

Bench: Shri George George K, Hon’Ble & Shri S.R. Raghunatha, Hon’Bleआयकर अपीलसं./Ita No.: 3323/Chny/2024 िनधा"रण वष" / Assessment Year: 2021-22

transfer pricing provisions even at times during which it was not an AE. All it posits is that the AE relationship may happen anytime during the year depending on facts and circumstances and it is only for that time period the international transactions between AE’s are subject to TP which in the instant case is 2 months of April