M/S.US TECHNOLOGY RESOURCES P. LTD,TRIVANDRUM vs. THE DCIT, TRIVANDRUM
In the result, the appeal for assessment year 2011-2012
ITA 475/COCH/2016[2012-13]Status: DisposedITAT Cochin11 May 2018AY 2012-13
Bench: Shri Chandra Poojari, Am & Shri George George K, Jm
For Appellant: Sri.Raghunathan S., AdvocateFor Respondent: Sri. Santham Bose, CIT-DR
Section 144C(5)Section 190Section 194JSection 234BSection 40Section 92C(3)
section 92C(3) of the Act, were satisfied in the instant case.
Accordingly, the order passed by the TPO is without jurisdiction.;
2.3. On the facts and in the circumstances of the case and in law, the learned TPO and accordingly, the learned AO erred in not demonstrating that the motive of the Appellant was to shift profits outside