SHENHZHEN SDG INFORMATION CO. LTD.,DELHI vs. CIRCLE INT. TAXATION 3(1)(2), DELHI

Appeal is allowed

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2017-18 Vs. Commissioner Of Income Tax, Shenhzhen Sdg Information Co. Ltd., International Taxation-3, C/O- Tass Advisors Llp, 62, New Delhi Lower Ground Floor, Pocket 2, Jasola, New Delhi Pan: Aavcs7426C (Appellant) (Respondent) Assessee By Sh. Divyanshu Agrawal, Adv. Sh. Anubhav Rastogi, Adv. Department By Sh. Vijay B Vasanta, Cit(Dr) Date Of Hearing 10.03.2025 Date Of Pronouncement 05.06.2025 Order

44B, 44BB, 44BBB of the Act provide rules for specified business activities carried out by the non-residents. However, under both, the objective is to arrive at the arm's length profit. The specific rules provide a pre-determined arm's length mark- up while under rule 10 the arm's length mark-up of profit is required

BRIJ GOPAL CONSTRUCTION COMPANY (P) LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE-3, DELHI

In the result, assessee’s appeal is allowed