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2 results for “disallowance”+ TP Methodclear

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Key Topics

Section 92C6Section 143(3)2Section 92A2Transfer Pricing2Exemption2Deduction2Addition to Income2Natural Justice2Comparables/TP2

SCORPIO IRON LTD,PANAJI vs. ITO, WARD - 1(4), PANAJI

In the result, both appeals of the assessee are allowed

ITA 388/PAN/2017[2013-14]Status: DisposedITAT Panaji07 Oct 2021AY 2013-14
For Appellant: Shri Shrinivas Nayak, CAFor Respondent: Shri Sourabh Nayak, Sr. DR
Section 143(3)Section 92ASection 92C

Method without any substantial justification. 14) The Id. AO(TP) has erred in applying the TNMM of companies which are no were similar to the business of the assesse w.r.t. type of business, turnover, assets base, business size, geographical area, sector in which the assesse operates, etc. The AO-TP has wilfully considered the comparable of 15) manufacturing concerns, whereas

SHREE AMBEY FORGING PRIVAT LIMITED,PANAJI vs. ITO, WARD - (4), PANAJI

In the result, both appeals of the assessee are allowed

ITA 389/PAN/2017[2013-14]Status: DisposedITAT Panaji07 Oct 2021AY 2013-14
For Appellant: Shri Shrinivas Nayak, CAFor Respondent: Shri Sourabh Nayak, Sr. DR
Section 143(3)Section 92ASection 92C

Method without any substantial justification. 14) The Id. AO(TP) has erred in applying the TNMM of companies which are no were similar to the business of the assesse w.r.t. type of business, turnover, assets base, business size, geographical area, sector in which the assesse operates, etc. The AO-TP has wilfully considered the comparable of 15) manufacturing concerns, whereas