ACIT CORPORATE, COCHIN vs. M/S.JOY ALUKKAS (INDIA) LTD, COCHIN
In the result, the appeal of the assessee is dismissed and the appeal of the
ITA 151/COCH/2015[2010-11]Status: DisposedITAT Cochin09 Apr 2018AY 2010-11
Bench: S/Shri Chandra Poojari , Am & George George K., Jm
Section 143(3)Section 144CSection 144C(5)Section 253Section 36(1)Section 36(1)(iii)Section 92CSection 92C(2)
gain as part of operating cost / operating income. The Safe
Harbour Rules are indicative of legislative intent and should have been followed.
3. The Dispute Resolution Panel failed to note that as per section 92C(2), as applicable to the relevant year, if the variation between ALP and the price at which the international transaction had been undertaken is less
