BILAKHIA HOLDING P LTD,VAPI vs. THE ACIT,VAPI CIRCLE, VAPI
In the result, the appeal of the assessee is allowed for assessment year 2010-11
ITA 181/SRT/2017[2009-10]Status: DisposedITAT Surat19 May 2021AY 2009-10
Bench: Shri Pawan Singh, Hon'Ble & Dr.Shri Arjun Lal Saini, Hon'Ble(Virtual Hearing) आ.अ.सं./I.T.A’S No.181 & 182/Srt/2017 "नधा"रण वष"/Assessment Years: 2009-10 & 2010-11 Bilakhia Holding P Ltd., Vs The Assistant Bilakhia House, Muktanand Marg, . Commissioner Of Income Chala, Surat – 394 520. Tax, Vapi Circle, Vapi. [Pan: Aadcs 4420 J] अपीलाथ" / Appellant ""यथ"/Respondent "नधा"रतीक"ओर से /Assessee By Shri Gopalakrishnan Aiyer – Ar राज"वक"ओर से /Revenue By Smt. Usha Shrote – Sr.Dr सुनवाई की तारीख/ Date Of Hearing: 13.04.2021 उ"घोषणा क" तार"ख/Pronouncement On: 19.05.2021 आदेश /O R D E R Per Dr.Arjun Lal Saini, Accountant Memeber: 1. Captioned Two Appeals Filed By Assessee Pertaining To Assessment Year 2009-10 & 2010-11, Are Directed Against The Separate Orders Passed By The Ld.Cit(A), Which In Turn Arise Out Of Separate Orders Passed By The Assessing Officer Under Section 271(1)(C) Of The Income Tax Act, 1961 (Here In After Referred To As The ‘Act’).
Section 143(3)Section 271Section 271(1)Section 271(1)(C)Section 271(1)(c)Section 274Section 92C
transfer pricing provisions. As regards, alternative rating that if at all the ALP has to be computed as provided in Rule 10B which is the machinery provision in this regard. Apparently, the TPO has considered and compared the rate of interest, risk margin and other factors applicable to corporate bonds and similar rated instruments in India. Thereafter he has arrived
