91 results for “transfer pricing”+ Section 65(1)clear
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In the result, the appeal filed by the assessee stands partly allowed for statistical purposes
Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm Assessment Year: 2020-21 Apollo Tyres Ltd. .......... Appellant 3Rd Floor, Areekal Mansion, Panampilly Nagar, Kochi 682036 [Pan: Aaaca6990Q] Vs. Acit, Corporate Circle-1(1), Kochi ......... Respondent Assessee By: Shri Abraham Joseph Markos, Adv. Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 20.08.2025 Date Of Pronouncement: 10.09.2025
65,197/- of R&D Revenue Expense and Rs. 1,40,38,500/- of R&D Capital Expense as claimed by the Appellant under section 35(2AB) of the Act in respect of expenditure incurred by it for its in-house R&D facility. b. The Ld. AO/DRP failed to appreciate that all the requisite pre-conditions