THE ACIT, 1(1), BHOPAL vs. M/S. ANDRITZ HYDRO PVT. LTD., RAISEN

In the result, grounds taken by the assessee in all the years with respect to provision of warranty are allowed

Bench: Shri D.T. Garasia & Shri O.P. Meena

method Page 46 of 84 M/s. Andritz Hydro Pvt. Ltd v DCIT/ T.P.A. No.157/Ind/2015 &316/Ind/2016/ A.Y.:10-11&11-12 DCIT vs. Andritz Hydro Pvt. Ltd T.P. A. No. 265/Ind/2015 & 349/Ind/2016/A.Y.:10-11&11-12 for the purpose of benchmarking the impugned International, whereas the approach proposed by the TPO for the year under appeal is absolute contradiction

M/S ANDRITZ HYDRO PRIVATE LIMITED (EARLIER KNOWN AS V A TECH HYDRO INDAI PVT. LTD.),MANDIDEEP vs. THE ACIT 1(1), BHOPAL

In the result, grounds taken by the assessee in all the years with respect to provision of warranty are allowed

Bench: Shri D.T. Garasia & Shri O.P. Meena

method Page 46 of 84 M/s. Andritz Hydro Pvt. Ltd v DCIT/ T.P.A. No.157/Ind/2015 &316/Ind/2016/ A.Y.:10-11&11-12 DCIT vs. Andritz Hydro Pvt. Ltd T.P. A. No. 265/Ind/2015 & 349/Ind/2016/A.Y.:10-11&11-12 for the purpose of benchmarking the impugned International, whereas the approach proposed by the TPO for the year under appeal is absolute contradiction

THE DCIT1(1), INDORE vs. M/S. AGRAWAL COAL CORPORATION P LTD., INDORE

Bench: Shri D.T. Garasia & Shri O.P. Meena

method. TPO also could not show any material or evidence to doubt the long-term contract of AE with third party. TPO also could not give any sustainable arguments to reject functional analysis conducted by appellant. Considering all the five arguments given above, I find no basis to sustain artificial bifurcation of profit arising to AE from one particular purchase

M/S. AGRAWAL COAL CORPORATION P. LTD.,INDORE vs. THE DCIT RANGE 1(1), INDORE

Bench: Shri D.T. Garasia & Shri O.P. Meena

method. TPO also could not show any material or evidence to doubt the long-term contract of AE with third party. TPO also could not give any sustainable arguments to reject functional analysis conducted by appellant. Considering all the five arguments given above, I find no basis to sustain artificial bifurcation of profit arising to AE from one particular purchase

M/S. AGRAWAL COAL CORPORATION P. LTD.,INDORE vs. THE DCIT -CIRCLE 1(1), INDORE

Bench: Shri D.T. Garasia & Shri O.P. Meena

method. TPO also could not show any material or evidence to doubt the long-term contract of AE with third party. TPO also could not give any sustainable arguments to reject functional analysis conducted by appellant. Considering all the five arguments given above, I find no basis to sustain artificial bifurcation of profit arising to AE from one particular purchase

THE DCIT-1(1), INDORE vs. M/S. AGRAWAL COAL CORPORATION P. LTD., INDORE

Bench: Shri D.T. Garasia & Shri O.P. Meena

method. TPO also could not show any material or evidence to doubt the long-term contract of AE with third party. TPO also could not give any sustainable arguments to reject functional analysis conducted by appellant. Considering all the five arguments given above, I find no basis to sustain artificial bifurcation of profit arising to AE from one particular purchase

THE ACIT ,CENTRAL-1, INDORE vs. M/S PRAKASH OILS LTD., DHAR

In the result, the above captioned appeals filed by the Revenue as well as the

Bench: Shri C.M. Garg & Shri Bhagirath Mal Biyani

TDS, obtaining of PAN of the Payee- transporter alone is sufficient and no further confirmation letters were required. It was also held that sections 194C(6) of the Act and Section 194C(7) of the Act are independent of each other, and cannot be read together to attract disallowance u/s 40(a)(ia) read with Section 194C

THE ADDL. CIT RANGE -1, INDORE vs. M/S PRAKASH OILS LTD., DHAR

In the result, the above captioned appeals filed by the Revenue as well as the

Bench: Shri C.M. Garg & Shri Bhagirath Mal Biyani

TDS, obtaining of PAN of the Payee- transporter alone is sufficient and no further confirmation letters were required. It was also held that sections 194C(6) of the Act and Section 194C(7) of the Act are independent of each other, and cannot be read together to attract disallowance u/s 40(a)(ia) read with Section 194C

THE ACIT,CENTRAL-1, INDORE vs. M/S PRAKASH OILS LTD., DHAR

In the result, the above captioned appeals filed by the Revenue as well as the

Bench: Shri C.M. Garg & Shri Bhagirath Mal Biyani

TDS, obtaining of PAN of the Payee- transporter alone is sufficient and no further confirmation letters were required. It was also held that sections 194C(6) of the Act and Section 194C(7) of the Act are independent of each other, and cannot be read together to attract disallowance u/s 40(a)(ia) read with Section 194C