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
Transfer Pricing Officer 3(2)(2)
(“TPO”) for determination of arm’s length price of the specified domestic transactions (“SDT”)
/
international transactions undertaken by the Applicant.
9. The TPO vide order dated 30 January 2019 held that the applicant has earned more than ordinary profits from its Section 80-IC business and proposed an adjustment of Rs.5,69