MANPOWERGROUP SERVICES INDIA PRIVATE LIMITED,DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2, DELHI , JHANDEWALAN EXTENSION, NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri Mahavir Singh & Shri Naveen Chandra

condone the delay of one day in filing Form 10DA. Ground 2 is allowed. 28. The ground no 3 raises the issue of allowance of 30% of additional employee cost as deduction for three consecutive years under Section 80JJAA. The assessee during AY 2020-21, the assessee has claimed deduction u/s 80JJAA of Rs. 36,28,32,847 which

M/S. NOKIA SOLUTIONS AND NETWORKS INDIA PVT. LTD.,GURGAON vs. DCIT, NEW DELHI

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastavaassessment Year: 2006-07 Nokia Solutions & Networks India Pvt. Ltd., Vs Dcit, (Formerly Known As Nokia Siemens Circle-18(2), Networks Pvt. Ltd.), 7Th Floor, Room No. 406, Building No. 9A, Dlf Cyber City, C.R. Building, Sector 25A, I.P. Estate, Gurgaon-122002 New Delhi. (Pan: Aaccn3871F) (Appellant) (Respondent) Appellant By: Shri Deepak Chopra, Adv. Respondent By: Shri T.M. Shiva Kumar, Cit Dr

92D of the Act read with Rule 10D of the Rules. 4.3 That the learned TPO erred, on facts and in law, in using single year financial data (i.e. data for FY 2005-06 only) as against multiple year financial data used by the Appellant for determination of the arm's length price of impugned transaction. 4.4 That the learned

SURYA ROSHNI LIMITED,NEW DELHI vs. PRINCIPAL COMMISSIONER OF INCOME TAX - 7, NEW DELHI

In the result, appeal filed by the assessee is allowed

92D(3) of\nthe Act, the AO may direct that such person shall pay, by way of penalty, a sum equal to 2%\nof the value of such transactions.\"\n\nAccordingly, Rs.4,57,61,447/- i.e. 2% of Rs.2,28,80,72,332/- should be levied as\npenalty u/s 271G of the Act.\n\n2.\nFurther, it is also noticed

PR. COMMISSIONER OF INCOME TAX-7 vs. SMR AUTOMOTIVE SYSTEMS INDIA LTD.

condonation of delay of 54 days in filing the appeal] 2. This appeal concerns Assessment Year (AY) 2014-15. 3. Broadly, the only issue which arises for consideration is as to whether the Income Tax Appellate Tribunal [in short, “Tribunal] was correct in holding that the Specified Domestic Transactions (SDTs) did not attract the regime of transfer pricing, in view