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)
section 92(A)(1) of the Act, because once the Assessing
Officer refers the transactions to TPO, he will be bound to act in conformity with the order of TPO as mandated by section 92CA(4) of the Act. The Ld. AR referred to Instruction No.3/2003, dated 20.05.2013, which is under old scheme, copy of which is placed