CITYSTAR GANGULY PROJECTS LLP,KOLKATA vs. PRINCIPAL CIT - 9, , KOLKATA

In the result, the appeal of the assessee is allowed

Bench: Shri J. Sudhakar Reddy, Am & Shri A. T. Varkey, Jm ]

Properties Investment (2014) reported in 51 taxmann 387 (SC) where it has been held that - ' PAN cannot be treated as sufficient disclosure of identity of the person. PANs are allowed on the basis of application without actual de facto clarification of identity or ascertainment of activities, nature of business activity and are just as to 2 I.T.A No.1103/Kol/2019

DCIT, CENTRAL CIRCLE - 2(1), KOLKATA , KOLKATA vs. M/S. PAHARPUR COOLING TOWERS LTD., , KOLKATA

Bench: Shri S.S.Godara & Dr. A.L.Saini

house for itself. Therefore, from the perspective of the recipient, if it were not something that he would have paid for, the activity should normally not be considered as an intra-group service under the arm's length principle. Given that Indian TP law differs from the OECD's approach in certain aspects with respect to the application

DCIT, CENTRAL CIRCLE - 2(1), KOLKATA , KOLKATA vs. M/S. PAHARPUR COOLING TOWERS LTD., , KOLKATA

Bench: Shri S.S.Godara & Dr. A.L.Saini

house for itself. Therefore, from the perspective of the recipient, if it were not something that he would have paid for, the activity should normally not be considered as an intra-group service under the arm's length principle. Given that Indian TP law differs from the OECD's approach in certain aspects with respect to the application

DCIT, CENTRAL CIRCLE - 2(1), KOLKATA , KOLKATA vs. M/S. PAHARPUR COOLING TOWERS LTD., , KOLKATA

Bench: Shri S.S.Godara & Dr. A.L.Saini

house for itself. Therefore, from the perspective of the recipient, if it were not something that he would have paid for, the activity should normally not be considered as an intra-group service under the arm's length principle. Given that Indian TP law differs from the OECD's approach in certain aspects with respect to the application