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Section 808 Section 80I6 Section 143(3)4 Section 144C2 Section 92C2 Section 92B2 Transfer Pricing2 Deduction2 Comparables/TP2

KARAM SAFETY PRIVATE LIMITED,SITARGANJ vs. THE INCOME TAX OFFICER, WARD-2(3)(5), UDHAM SINGH NAGAR

In the result, both the appeals of the assessee are allowed and that of the Stay Applications are dismissed

ITA 24/DDN/2022[2018-19]Status: DisposedITAT Dehradun23 May 2023AY 2018-19

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

For Appellant: Sh. Nageshwar Rao, AdvFor Respondent: Sh. Pramod Verma, CIT DR

Section 143(3)Section 144CSection 80Section 80ISection 92BSection 92C

disallowing deduction u/s 80IC/Chapter VI-A of the Act. 4. On the facts and circumstances of the case and in law, the Ld. AO/DRP have failed to appreciate that to invoke the provisions of Section 92BA, existence of any 'arrangement' to ‘more than ordinary profits’ between the Appellant and its Associate Enterprise (“AE”) need to be established under the provisions

KARAM SAFETY PRIVATE LIMITED,SITARGANJ vs. THE INCOME TAX OFFICER, WARD-2(3)(5), UDHAM SINGH NAGAR

KARAM SAFETY PRIVATE LIMITED,SITARGANJ vs. THE INCOME TAX OFFICER, WARD-2(3)(5), UDHAM SINGH NAGAR

KARAM SAFETY PRIVATE LIMITED,UDHAM SINGH NAGAR vs. THE INCOME TAX OFFICER, WARD-2(3)(5), UDHAM SINGH NAGAR