NAV MAHARASHTRA CHAKAN OIL MILLS LTD,PUNE vs. INCOME TAX OFFICER, WARD-2(4), PUNE, PUNE
In the result, appeal of the assessee is allowed for statistical purpose
ITA 1871/PUN/2024[2013-14]Status: DisposedITAT Pune22 Oct 2024AY 2013-14
Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1871 & 1872/Pun/2024 िनधा"रण वष" / Assessment Years: 2013-14 & 2014-15 Nav Maharashtra Chakan Oil V The Income Tax Officer, Mills Limited, S Ward-2(4), Pune. 43, Nav Maharashtra House, Near Shaniwar Wada, Shaniwar Peth, Pune – 411030. Pan: Aaacn9941J Appellant / Assessee Respondent / Revenue Assessee By Shri Nikhil Pathak – Advocate Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 16/10/2024 Date Of Pronouncement 22/10/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Are Two Appeals Filed By The Assessee Against The Two Separate Orders Of Ld.Commissioner Of Income Tax(Appeal), Pune Dated 27.07.2022 & 20.11.2023 For A.Y.2013-14 & 2014-15 Respectively. Since The Issue Involved Is Common, Both These Appeals Were Heard Together & Decided By The Common Order.
Section 250(6)Section 92B
40A(2)(b) in respect of which TP Adjustment made by the learned TPO/AO and since the transfer pricing provisions were amended by Finance Act,
2017 to exclude specified domestic transactions which are under section 92BA read with 40(2)(6) from the purview of transfer pricing regulations, the said addition made of Rs.19,43,14,369/- was not justified