45 results for “transfer pricing”+ Carry Forward of Lossesclear
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Bench: Shri Vijay Pal Rao & Shri B.M. Biyanicomputer Sciences Dcit, Circle 11(4) Corporation India Private No. 14/3, 5Th Floor, R.P. Limited Bhawan Nrupathunga (Formerly Isoft Health Road Vs. Management (India) Pvt. Bangalore Ltd.) Unit-13, Block-2, Sdf Building Mpez Bhopal (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaaco 2465N Assessee By Shri Vishal Kalra, Ar Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 03.08.2023 Date Of Pronouncement 21.08.2023
loss to find any merit in the contention raised on behalf of the Department. Para 3.7 of the Instruction clearly states that: "For administering the transfer pricing regime in an efficient manner, it is clarified that though the AO has the power u/s. 92C to determine the ALP of an international transaction or specified domestic transaction, determination of ALP should