2 results for “transfer pricing”+ Section 56(2)(vii)clear
Sorted by relevance
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
56 (Income from other Sources). Even Income arising from International Transaction between A.E. must satisfy the test of Income under the Act and must find its home in one of the above heads i.e. charging provisions..... iv. Dana Corporation [2010] 186 Taxman 187 (MR) The relevant extracts are as follows: "8. ............ It must be noted that Section