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 adjustment exercise." ix. Vijai Electricals Limited [2013] 36 Taxman 386 (AAR) "The learned counsel relied upon the decision in the case of Dana Corpn., In re [2010] 321 ITR 178/186 Taxman 187 (MR-New Delhi) wherein it has been held as follows: Section 92 is not an independent charging provision. The expression 'income arising' in the opening words