BharatTax.net
SearchITATHigh CourtsSupreme CourtPhrasesAI ResearchHistory

Filters

BharatTax.net

Free search engine for ITAT (Income Tax Appellate Tribunal) judgments across all 28 benches in India.

Quick Links

  • Search Judgments
  • Browse by Bench
  • Recent Judgments

About

BharatTax provides free access to Income Tax Appellate Tribunal orders for legal research and reference.

© 2026 BharatTax.net. All rights reserved.

29 results for “capital gains”+ Section 92C(3)clear

Sorted by relevance

Mumbai274Bangalore216Delhi214Ahmedabad62Kolkata61Chennai35Pune29Hyderabad22Indore11Jaipur7Surat5Guwahati5Cochin4Visakhapatnam3Panaji1Karnataka1Jabalpur1Amritsar1

Key Topics

Section 92C(3)29Section 143(3)26Addition to Income24Transfer Pricing21Comparables/TP19Section 10A17Section 144C(8)12Section 92C(2)9Section 115J9Section 92C

M/S. SAVA HEALTHCARE LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

ITA 1066/PUN/2017[2011-12]Status: DisposedITAT Pune27 Jun 2019AY 2011-12

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)

capital employed based, floor area base, headcount base, etc. He then pointed out that it was a fit case to resort to average allocation ratio i.e. average of assets plus expenses allocation keys and pointed out that the steps to be taken in this regard which are reproduced at page 83 of TPO’s order. The TPO thus, worked

Showing 1–20 of 29 · Page 1 of 2

9
Section 10A(7)8
Deduction6

M/S. SAVA HEALTHCARE LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

ITA 1064/PUN/2017[2009-10]Status: DisposedITAT Pune27 Jun 2019AY 2009-10

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)

capital employed based, floor area base, headcount base, etc. He then pointed out that it was a fit case to resort to average allocation ratio i.e. average of assets plus expenses allocation keys and pointed out that the steps to be taken in this regard which are reproduced at page 83 of TPO’s order. The TPO thus, worked

M/S. SAVA HEALTHCARE LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

ITA 1062/PUN/2017[2007-08]Status: DisposedITAT Pune27 Jun 2019AY 2007-08

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)

capital employed based, floor area base, headcount base, etc. He then pointed out that it was a fit case to resort to average allocation ratio i.e. average of assets plus expenses allocation keys and pointed out that the steps to be taken in this regard which are reproduced at page 83 of TPO’s order. The TPO thus, worked

M/S. SAVA HEALTHCARE LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

ITA 1065/PUN/2017[2010-11]Status: DisposedITAT Pune27 Jun 2019AY 2010-11

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)

capital employed based, floor area base, headcount base, etc. He then pointed out that it was a fit case to resort to average allocation ratio i.e. average of assets plus expenses allocation keys and pointed out that the steps to be taken in this regard which are reproduced at page 83 of TPO’s order. The TPO thus, worked

M/S. SAVA HEALTHCARE LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

ITA 1063/PUN/2017[2008-09]Status: DisposedITAT Pune27 Jun 2019AY 2008-09

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)

capital employed based, floor area base, headcount base, etc. He then pointed out that it was a fit case to resort to average allocation ratio i.e. average of assets plus expenses allocation keys and pointed out that the steps to be taken in this regard which are reproduced at page 83 of TPO’s order. The TPO thus, worked

M/S. SAVA HEALTHCARE LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

ITA 1067/PUN/2017[2012-13]Status: DisposedITAT Pune27 Jun 2019AY 2012-13

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)

capital employed based, floor area base, headcount base, etc. He then pointed out that it was a fit case to resort to average allocation ratio i.e. average of assets plus expenses allocation keys and pointed out that the steps to be taken in this regard which are reproduced at page 83 of TPO’s order. The TPO thus, worked

QUBIX BUSINESS PARK PRIVATE LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-8, PUNE, PUNE

In the result, Ground No.2 of the assessee is allowed for statistical purpose

ITA 1994/PUN/2024[2020-21]Status: DisposedITAT Pune06 Jan 2025AY 2020-21

Bench: DR.DIPAK P. RIPOTE (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

Section 115JSection 143(3)Section 144BSection 144C(13)Section 144C(5)Section 80

Capital Gains amounting to Rs.2,57,47,042/-. Assessee relied on the decision of Hon’ble Supreme Court in the case of CIT-I Vs. Reliance Energy Ltd.(supra) [2022] 441 ITR 346 (SC). The Dispute Resolution Panelheld that there is no variation proposed in the Draft Assessment Order with reference to Assessee’s claim of deduction under section 80IAB

ACIT,CIR.-1,, AURANGABAD vs. SKODA AUTO INDIA PVT. LTD.,, AURANGABAD

In the result, appeal of the assessee in ITA No

ITA 714/PUN/2011[2005-06]Status: DisposedITAT Pune02 Jul 2019AY 2005-06

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm आयकर अपीऱ सं. / Ita No.714/Pun/2011 नििाारण वषा / Assessment Year : 2005-06 The Assistant Commissioner Of Income Tax, Circle-1, Aurangabad. .......अऩीऱाथी / Appellant बिाम / V/S. Skoda Auto India Pvt. Ltd. Plot No.A1/1, Shendra Five Star Industrial Area, Midc, Aurangabad-431 201 Pan :Aaecs3749M ……प्रत्यथी / Respondent

For Appellant: Shri Nikhil Pathak &For Respondent: Shri Avadhesh Kumar, CIT

Gain Communications Pvt. Ltd. 118 TTJ 354 wherein it has been observed as under: “41. The learned DR had also raised some objection to the revised margin of profit shown by the taxpayer by taking lower rate of depreciation. This objection in our opinion is without any substance. The depreciation is required to be worked out under the Indian Companies

SKODA AUTO INDIA PVT. LTD.,,AURANGABAD vs. ASSISTANT COMMISSIONER OF INCOME-TAX,, PUNE

In the result, appeal of the assessee in ITA No

ITA 546/PUN/2014[2009-10]Status: DisposedITAT Pune02 Jul 2019AY 2009-10

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm आयकर अपीऱ सं. / Ita No.714/Pun/2011 नििाारण वषा / Assessment Year : 2005-06 The Assistant Commissioner Of Income Tax, Circle-1, Aurangabad. .......अऩीऱाथी / Appellant बिाम / V/S. Skoda Auto India Pvt. Ltd. Plot No.A1/1, Shendra Five Star Industrial Area, Midc, Aurangabad-431 201 Pan :Aaecs3749M ……प्रत्यथी / Respondent

For Appellant: Shri Nikhil Pathak &For Respondent: Shri Avadhesh Kumar, CIT

Gain Communications Pvt. Ltd. 118 TTJ 354 wherein it has been observed as under: “41. The learned DR had also raised some objection to the revised margin of profit shown by the taxpayer by taking lower rate of depreciation. This objection in our opinion is without any substance. The depreciation is required to be worked out under the Indian Companies

M/S. SCHLUMBERGER INDIA TECHNOLOGY CENTRE P. LTD.,,PUNE vs. DEPUTY DIRECTOR OF INCOME-TAX,,

In the result, appeal of the assessee is partly allowed

ITA 640/PUN/2014[2010-11]Status: DisposedITAT Pune10 Jan 2018AY 2010-11

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.640/Pun/2014 यििाारण वषा / Assessment Year :2010-11 M/S. Schlumberger India Technology Centre Pvt. Ltd., (Formerly Known As Schlumberger Global Support Centre Ltd.-India Branch) Office No.701, 7Th Floor, Building No.9, Commerzone, Survey No.144/145, Samrat Ashok Path, Off Airport Road, Yerwada अऩीऱाथी/Appellant Pune – 411006 …. Pan: Aalcs2048C Vs. The Dy. Director Of Income Tax (It)-Ii, …. प्रत्यथी / Respondent Pune

For Appellant: Shri Kamal SawhneyFor Respondent: Shri Rajeev Kumar, CIT
Section 143(3)Section 92C(3)Section 92D

gain arising on account of business operations from operating costs. 11 On the facts and in the circumstances of the case, and in law, the Ld. AO has erred in and the Honourable DRP has further erred in confirming the action of the Ld. AO of not allowing an adjustment for the difference between the level of risk borne

CUMMINS INDIA LIMITED,,PUNE vs. ACIT CIRCLE 1(1), PUNE

In the result, the appeal is partly allowed

ITA 2111/PUN/2019[2015-16]Status: DisposedITAT Pune28 Sept 2022AY 2015-16

Bench: Shri R.S. Syal & Shri S.S.Viswanethra Raviआयकर अपील सं. / Ita No.2111/Pun/2019 "नधा"रण वष" / Assessment Year : 2015-16

Section 143(3)

92C(1) of the Act should be done as per the most appropriate method. To put it more simply, each international transaction is viewed separately and independent of other international transactions for determining its ALP unless they are closely linked. It is impermissible to combine more than one unrelated international transaction for determining their ALP in a unified manner when

VOLKSWAGEN GROUP TECHNOLOGY SOLUTIONS INDIA PVT. LTD.,PUNE vs. NATIONAL FACELESS ASSESSMENT CENTER, ASSESSMENT UNIT DELHI, DELHI

In the result, appeal of the assessee is partly allowed

ITA 1950/PUN/2024[2020-21]Status: DisposedITAT Pune28 May 2025AY 2020-21

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1950/Pun/2024 िनधा"रण वष" / Assessment Year: 2020-21 Volkswagen Group Technology V National Faceless Solutions India Pvt. Ltd., S Assessment Center, Embassy Techzone, 9Th Floor, Assessment Unit, Delhi. 1.3 Congo Building, Rajiv Gandhi, Infotech Park, Infotech Park Hinjavadi, Pune – 411057. Maharashtra. Pan: Aafcv1368L Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil Pathak – Ar Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 15/05/2025 Date Of Pronouncement 28/05/2025

Section 143(3)Section 144BSection 153Section 92C(1)Section 92C(3)

Section 92C(1) and 92C(2) of the Act and the Ld. TPO has erred in disregarding the transfer pricing analysis carried out by the Appellant with respect to the international transaction of provision of IT services. 3. On the facts and in the circumstances of the case, and in law, the Ld. AO / Ld. TPO has erred passing

DEPUTY COMMISSIONER OF INCOME-TAX vs. M/S. HONEYWELL AUTOMATION INDIA LTD.,, PUNE

In the result, the appeal of Revenue is dismissed

ITA 619/PUN/2015[2003-04]Status: DisposedITAT Pune03 Mar 2020AY 2003-04

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

For Appellant: Shri Ajit Kumar JainFor Respondent: Shri T. Vijaya Bhaskar Reddy
Section 10ASection 10A(7)Section 251(2)

gains of an eligible business cannot be tinkered with by the Assessing Officer merely because they are more than the ordinary profits or that they are quite high. The existence of substantial or more than ordinary profits by itself does not sufficiently empower the Assessing Officer to disregard them and determine the profits which he may consider to be reasonably

M/S. HONEWELL AUTOMATION INDIA LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of Revenue is dismissed

ITA 583/PUN/2015[2003-04]Status: DisposedITAT Pune03 Mar 2020AY 2003-04

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

For Appellant: Shri Ajit Kumar JainFor Respondent: Shri T. Vijaya Bhaskar Reddy
Section 10ASection 10A(7)Section 251(2)

gains of an eligible business cannot be tinkered with by the Assessing Officer merely because they are more than the ordinary profits or that they are quite high. The existence of substantial or more than ordinary profits by itself does not sufficiently empower the Assessing Officer to disregard them and determine the profits which he may consider to be reasonably

M/S. SCHLUMBERGER INDIA TECHNOLOGY CENTRE PVT. LTD.,,PUNE vs. JOINT DIRECTOR OF INCOME-TAX,,

In the result, appeal of Revenue is dismissed and appeal of assessee is disposed of as indicated above

ITA 1280/PUN/2015[2011-12]Status: DisposedITAT Pune17 Jan 2018AY 2011-12

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.1264/Pun/2015 नििाारण वषा / Assessment Year : 2011-12 The Deputy Director Of Income Tax अऩीऱाथी / Appellant (International Taxation), Circle-2, Pune. … बिाम / V/S. M/S. Schlumberger India Technology Centre Pvt. Ltd., (Formerly Known As Schlumberger Global Support Centre Ltd.-India Branch) Office No. 701, 7Th Floor, Bldg. No. 9, Commerzone, Survey No.144/145, Samrat Ashok Path, Off Air Port Road, Yerwada, … प्रत्यथी / Respondent Pune-411 006. Pan :Aalcs2048C आयकर अपीऱ सं. / Ita No.1280/Pun/2015 नििाारण वषा / Assessment Year : 2011-12 M/S. Schlumberger India Technology Centre Pvt. Ltd., (Formerly Known As Schlumberger Global Support Centre Ltd.-India Branch) Office No. 701, 7Th Floor, Bldg. No. 9, Commerzone, Survey No. 144/145, Samrat Ashok Path, Off Air Port Road, Yerwada, अऩीऱाथी / Appellant Pune-411 006. … Pan :Aalcs2048C बिाम / V/S. The Joint Director Of Income Tax, … प्रत्यथी / Respondent (International Taxation), Pune. A.Y. 2011-12

For Appellant: Shri Rajeev Kumar, CITFor Respondent: Shri Kamal Sawhney & Shri Sujit Thakar
Section 143(3)Section 92C(3)Section 92D

3) of the Act were satisfied and not sharing the search strategy including the accept-reject matrices used before making an adjustment to the income of the Appellant. 4. On the facts and circumstances of the case, and in law, the Ld. AO erred in and the Ld. CIT(A) further erred in confirming the action

DEPUTY DIRECTOR OF INCOME-TAX vs. SCHLUMBERGER GLOBAL SUPPORT CENTRE LTD.,, PUNE

In the result, appeal of Revenue is dismissed and appeal of assessee is disposed of as indicated above

ITA 1264/PUN/2015[2011-12]Status: DisposedITAT Pune17 Jan 2018AY 2011-12

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.1264/Pun/2015 नििाारण वषा / Assessment Year : 2011-12 The Deputy Director Of Income Tax अऩीऱाथी / Appellant (International Taxation), Circle-2, Pune. … बिाम / V/S. M/S. Schlumberger India Technology Centre Pvt. Ltd., (Formerly Known As Schlumberger Global Support Centre Ltd.-India Branch) Office No. 701, 7Th Floor, Bldg. No. 9, Commerzone, Survey No.144/145, Samrat Ashok Path, Off Air Port Road, Yerwada, … प्रत्यथी / Respondent Pune-411 006. Pan :Aalcs2048C आयकर अपीऱ सं. / Ita No.1280/Pun/2015 नििाारण वषा / Assessment Year : 2011-12 M/S. Schlumberger India Technology Centre Pvt. Ltd., (Formerly Known As Schlumberger Global Support Centre Ltd.-India Branch) Office No. 701, 7Th Floor, Bldg. No. 9, Commerzone, Survey No. 144/145, Samrat Ashok Path, Off Air Port Road, Yerwada, अऩीऱाथी / Appellant Pune-411 006. … Pan :Aalcs2048C बिाम / V/S. The Joint Director Of Income Tax, … प्रत्यथी / Respondent (International Taxation), Pune. A.Y. 2011-12

For Appellant: Shri Rajeev Kumar, CITFor Respondent: Shri Kamal Sawhney & Shri Sujit Thakar
Section 143(3)Section 92C(3)Section 92D

3) of the Act were satisfied and not sharing the search strategy including the accept-reject matrices used before making an adjustment to the income of the Appellant. 4. On the facts and circumstances of the case, and in law, the Ld. AO erred in and the Ld. CIT(A) further erred in confirming the action

RENISHAW METROLOGY SYSTEMS LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 5,, PUNE

In the result, appeal of the assessee is dismissed

ITA 619/PUN/2021[2013-14]Status: DisposedITAT Pune24 Jan 2024AY 2013-14

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripoteआयकर अपीलसं. / Ita No.619/Pun/2021 िनधा"रण वष" / Assessment Year : 2013-14 Renishaw Metrology Systems The Dy.Commissioner Limited, V Of Income Tax, Circle- S.No.283, Hissa No.2, S.No.284, S 5, Pune. Hissa No.2 & 3A, Raisoni Estate, Taluk – Mulshi, Dist-Pune. Pan: Aabcr6361F Appellant/ Assessee Respondent /Revenue Assessee By Shri Ajit Jain & Shri Siddesh Chaugule – Ar’S Revenue By Shri Suhas Kulkarni – Addl. Cit(Dr) Date Of Hearing 04/01/2024 Date Of Pronouncement 24/01/2024

Section 194ASection 271Section 92C(2)Section 92C(3)Section 92D

92C(3) of the Act were satisfied before making an adjustment to the income of the Appellant. Renishaw Metrology Systems Ltd., [A] 2. Transfer Pricing adjustment in respect of Software Development Services 2.1 disregarding the benchmarking analysis and comparable companies selected by the Appellant in the transfer pricing study report maintained as per Section 92D of the Act read with

ASSISTANT COMMISSIONER OF INCOME-TAX vs. M/S. KPIT TECHNOLOGIES LTD.,, PUNE

In the result, appeal of assessee relating to assessment year 2008-09 is partly allowed, appeal of assessee relating to assessment year 2009-10 and appeal of Revenue are partly allowed

ITA 459/PUN/2014[2009-10]Status: DisposedITAT Pune09 Apr 2018AY 2009-10

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.246/Pun/2013 यििाारण वषा / Assessment Year : 2008-09

For Appellant: Shri Kishore PhadkeFor Respondent: Shri Rajeev Kumar, CIT
Section 10ASection 143(3)Section 37(1)Section 92CSection 92C(2)

3. The learned AO and DRP erred in law and on facts in not allowing entire payment of Rs 20,18,75,000 (5 Million USD) for acquisition of Right to Render BPO Services" as deductible expenditure u/s 37(1). 4. The learned AO, TPO and DRP erred in law and on facts in determining, u/s 92CA

KPIT CUMMINS GLOBAL BUSINESS SOLUTIONS LTD., (NOW MERGED WITH KPIT CUMMINS INFOSYSTEMS LTD),PUNE vs. ACIT, CIRCLE 11(1), PUNE

In the result, appeal of assessee relating to assessment year 2008-09 is partly allowed, appeal of assessee relating to assessment year 2009-10 and appeal of Revenue are partly allowed

ITA 246/PUN/2013[2008-09]Status: DisposedITAT Pune09 Apr 2018AY 2008-09

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.246/Pun/2013 यििाारण वषा / Assessment Year : 2008-09

For Appellant: Shri Kishore PhadkeFor Respondent: Shri Rajeev Kumar, CIT
Section 10ASection 143(3)Section 37(1)Section 92CSection 92C(2)

3. The learned AO and DRP erred in law and on facts in not allowing entire payment of Rs 20,18,75,000 (5 Million USD) for acquisition of Right to Render BPO Services" as deductible expenditure u/s 37(1). 4. The learned AO, TPO and DRP erred in law and on facts in determining, u/s 92CA

KPIT CUMMINS GLOBAL BUSINESS SOLUTIONS LTD.,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX,,

In the result, appeal of assessee relating to assessment year 2008-09 is partly allowed, appeal of assessee relating to assessment year 2009-10 and appeal of Revenue are partly allowed

ITA 525/PUN/2014[2009-10]Status: DisposedITAT Pune09 Apr 2018AY 2009-10

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.246/Pun/2013 यििाारण वषा / Assessment Year : 2008-09

For Appellant: Shri Kishore PhadkeFor Respondent: Shri Rajeev Kumar, CIT
Section 10ASection 143(3)Section 37(1)Section 92CSection 92C(2)

3. The learned AO and DRP erred in law and on facts in not allowing entire payment of Rs 20,18,75,000 (5 Million USD) for acquisition of Right to Render BPO Services" as deductible expenditure u/s 37(1). 4. The learned AO, TPO and DRP erred in law and on facts in determining, u/s 92CA