UST GLOBAL TECHNOLOGY SERVICES (INDIA) PRIVATE LIMITED,KOCHI vs. DCIT,CORPORATE CIRCLE 2(1), KOCHI

In the result, appeal filed by the assessee stands partly allowed\nfor statistical purpose and the stay application is dismissed as\ninfructuous

Section 92C(3) of the Act.\n1.2 The Ld. AO/Ld. TPO/Ld. Panel have erred in not\ndemonstrating that the motive of the Appellant was to shift profits\noutside of India by manipulating the prices charged in its\ninternational transactions, which is a pre-requisite condition to\nmake any adjustment under the provision of Chapter

US TECHNOLOGY INTERNATIONAL P. LTD,TRIVANDRUM vs. THE ACIT, TRIVANDRUM

In the result, appeal filed by the assessee is partly allowed of statistical purposes