SEMPERTRANS INDIA PRIVATE LIMITED,ROHA vs. INCOME-TAX OFFICER, PANVEL
In the result, appeal filed by the assessee is partly\nallowed for statistical purposes
ITA 1778/PUN/2024[AY 2020-21]Status: DisposedITAT Pune14 Nov 2025
Section 144Section 144CSection 144C(8)Section 153Section 92CSection 92D
92D of the Act read with Rule 10D of the\nIncome Tax Rules, 1962 ('Rules').\n8. Upholding/confirming the action of Ld. TPO, in going beyond\nthe scope under section 92CA in questioning the commercial\nrationale of the legitimate business expenses incurred by the\nAppellant and further erred in determining the ALP of payment of\nservices to be NIL.\n9. Rejecting
