M/S PUNJAB INSTITUTE OF MEDICAL SCIENCES, GARHA ROAD , JALANDHAR vs. COMMISSIONER OF INCOME TAX JALANDHAR AND ANR

Bench: MR. JUSTICE SANJEEV PRAKASH SHARMA,MR. JUSTICE SANJAY VASHISTH

transferring 1.65 acres of land from Punjab Agriculture University, Ludhiana to PIMS-Society, Jalandhar. The Governing Council was formed headed by Chief Minister. A Director was appointed by the State Government. The society was registered in 1994. The State Government granted a sum of ` 3 crores in the year 1994-95. In 1996, an Architect was appointed to prepare master

THE PR. COMMISSIONER OF INCOME TAX GURGAON vs. M/S EQUANT SOLUTIONS INDIA PVT LTD

Appeals stand disposed of in the above terms

Bench: MR. JUSTICE AJAY TEWARI,MRS. JUSTICE ALKA SARIN

13 comparables with a mean OP/TC of 12.12%. The OP/TC earned by the assessee under both the segments was 15.02%. Thus, it was contended on behalf of the assessee that its transactions with the associated enterprises are at arms length. 4. A reference was made to the transfer pricing officer to determine the arms length price. The transfer Pricing officer