Search: transfer pricing

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EVALUESERVE SEZ (GURGAON) PVT. LTD.,GURGAON vs. ACIT, NEW DELHI

In the result, the appeal of the assessee is partly allowed with above direction

ITA 1467/DEL/2015[2010-11]Status: DisposedITAT Delhi29 Jun 2017AY 2010-11

Bench: Bhavnesh Saini & Shri Prashant Maharishievalueserve Sez (Gurgaon) Vs. Assistant Commissioner Of Private Ltd, Income Tax, Circle-8(2), 8Th, 9Th & 10Th Floor, Building New Delhi No. 04, Unitech Realty Projects Ltd, Sez, Tikri, Sector-48, Gurgaon Harya-122002 Pan:Aabce8812A (Appellant) (Respondent)

For Appellant: Ms. Ananya Kapoor, AdvFor Respondent: Shri. Amrendra Kumar, CIT DR

Section 143(3)Section 144CSection 144C(5)Section 92Section 92CSection 92D

Transfer Pricing Officer out of the 10 comparables of the assessee accepted only 2 comparables and on its own search included further 10 comparables accepting the PLI of the OP/OC of the assessee determined the average margin of the comparables at 33.14%. Subsequently, the above adjustment was incorporated in draft assessment order dated 12.03.2014 against which the objections were filed

COMMISSIONER OF INCOME TAX DELHI vs. M/S D.T.T.D.C. LTD. NEW DELHI

Appeals are disposed of

ITA/166/2001HC Delhi20 Mar 2012

Bench: HON'BLE MR. JUSTICE SANJIV KHANNA,HON'BLE MR. JUSTICE R.V.EASWAR

For Respondent: ITAs 166/01, 161/04, 320/04 & ITR 30-33/1997

Section 256(1)Section 617

transfer of income by way of overriding title retrospectively. The letter would be effective on or after 6th February, 1992. 24. We are in agreement with the Revenue that the question of diversion of income by way of overriding title till letter dated 5th February, 1992 was issued does not arise. However, till that date i.e. 5th February