TATA CUMMINS PRIVATE LIMITED,PUNE vs. THE DCIT CIRCLE-1-JAMSHEDPUR AND THE ASSESSMENT UNIT, INCOME-TAX DEPARTMENT, NFAC, DELHI, JAMSHEDPUR

In the result, appeal of the assessee is partly allowed for statistical purposes

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaytata Cummins Private Limited, D.C.I.T., Cummins India Office, Tower-A, 7Th Circle-1, Vs. Floor, Survey No. 21, Balewadi, Pune, Jamshedpur. Maharashtra. Pan No. Aaact 6353 L Appellant/ Assessee Respondent/ Revenue

Transfer Pricing Guidelines, para 7.13 emphasises that there should not be any automatic inference about an AE receiving an entity group service only because it gets on incidental benefit for being part of a larger concern and not to any specific activity performed" 10.14 In addition, the Assessee further submits that the commercial expediency/ business rationale of a particular expenditure

SUDHIR KUMAR JHA,BOKARO STEEL CITY vs. ACIT OR DCIT, CIRCLE-3, BOKARO

In the result, the appeal of the assessee is dismissed