519 results for “disallowance”+ Transfer Pricingclear
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In the result, the appeal of the Revenue is dismissed
Bench: Invoking Section 80La( 10) , Of The Act When Bare Reading Of The Provision Does Not Impose Such Burden Of Proving Tax Avoidance On A.O.? 3. Whether On The Facts, Circumstances Of The Case And- In Law, Ld. Commissioner Of Income Tax (Appeals) Was Justified In Interpreting The Words According To The Object Of The Provision Ignoring The Fundamental Principle Of Interpretation Of Stature That Nothing Should Be Added To The Words Used By Legislature? 4. Whether On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Was Justified In Imposing Burden Of Proving Tax Avoidance Ignoring The Fact That Section 80Ia(10) Of The Act Is A “Domestic Transfer Pricing” Provision & Proving Tax Avoidance Is Not One
transfer pricing provisions? 5. Whether on the facts and circumstances of the case and in law, the ld. CIT(A) was justified in concluding that net profit of the assessee would not be considered “more than ordinary” and disregarding the fact that tax avoidance is resulted because of claiming excessive deduction u/s 10A on net profit component of “more than