DCIT, INTERNATIONAL TAXATION, CIRCLE GURGAON , GURUGRAM vs. LUMMUS TECHNOLOGY HEAT TRASFER BV- INDIA BRANCH OFFICE , GURGAON

In the result, the appeals of the Revenue are dismissed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

44D on gross basis by holding that the fact of subsequent years 2008-09 and 2009-10 were similar to this assessment year. 3. Whether, on the facts and in circumstances of the case, the Ld. CIT(A) has erred in deleting the penalty U/s 271(1)(c) of the Income Tax Act, 1961 on rejecting the Transfer Pricing adjustment

DCIT, INTERNATIONAL TAXATION, CIRCLE GURGAON , GURUGRAM vs. LUMMUS TECHNOLOGY HEAT TRASFER BV- INDIA BRANCH OFFICE , GURGAON