VAIBHAV GLOBAL LIMITED,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5, JAIPUR
In the result, the penalty is directed to be deleted and appeal of the assessee is allowed
ITA 730/JPR/2018[2009-10]Status: DisposedITAT Jaipur19 Dec 2018AY 2009-10
For Appellant: Shri Vijay Mehta (C.A.) &For Respondent: Smt. Roli Agarwal (CIT)
Section 143(3)Section 271(1)(c)Section 92C
92B, it is clear that lending or borrowing of money between two associated enterprises comes within the admit of international transaction and whether the same is at arm’s length has to be considered. Further, the adjustment made by the AO was confirmed at various levels i.e. DRP, ITAT and even the Hon’ble High Court with slight variation