DCIT(IT)-2(2)(2), NARIMAN POINT vs. THE HONGKONG AND SHANGHAI BANKING CORPORATION LTD, BANDRA

92C of tlie Income-tax Act, 1961 ('The Act'). Based on the said study, having regard to commercial\nand cronomic lactors, the amount paid/payable or received receivable in respect of the above transaction has been computed by the assessee, having regard\nto the arm's length price.\nNuto'st Seeneding to the assestre, the above mentioned transactione has been entered

THE HONGKONG AND SHANGHAI BANKING CORPORATION LIMITED -INDIA BRANCHES ,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-2(2)(2), MUMBAI

92C of tlie Income-tax Act, 1961 ('The Act'). Based on the said study, having regard to commercial\nand cronomic lactors, the amount paid/payable or received receivable in respect of the above transaction has been computed by the assessee, having regard\nto the arm's length price.\nNuto'st Seeneding to the assestre, the above mentioned transactione has been entered

THE HONGKONG AND SHANGHAI BANKING CORPORATION LIMITED INDIA BRANCHES ,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-2(2)(2), MUMBAI

92C of tlie Income-tax Act, 1961 ('The Act'). Based on the said study, having regard to commercial\nand cronomic lactors, the amount paid/payable or received receivable in respect of the above transaction has been computed by the assessee, having regard\nto the arm's length price.\nNuto'st Seeneding to the assestre, the above mentioned transactione has been entered

SHELL INDIA MARKETS P.LTD,MUMBAI vs. CIT LTU, MUMBAI

In the result, appeal of the assessee is allowed

Bench: Shri R.C. Sharma (A.M.) & Shri Pawan Singh (Jm) Shell India Markets Pvt Ltd Vs Commissioner Of Income-Tax- Trent House, First Floor, Large Tax Units (Ltu) G-Block, Plot No.C-60, Mumbai Bandra Kurla Complex, Bandra (E) Mumbai-400 051 Pan : Aaics1404P Appellant Respondednt

92C(4) and the order passed by AO is erroneous as the same is passed without making necessary enquiries. The order is prejudicial to the interest of revenue. By allowing deduction u/s 10B by the AO, the department has suffered loss of revenue and accordingly the assessment order is not only erroneous but also prejudicial to the interest of revenue

DCIT(CC)-8(3), MUMBAI vs. 63 MOONS TECHNOLOGIES LIMITED, MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

reassessment proceedings. Reasons to believe recorded by the ld. Assessing Officer does not advert to any fresh tangible material which has come in his possession after the conclusion of the original assessment proceedings. They only make reference to the Assessment Order for AY 2014-15 and notes to account to the financial statement which in no way constitute fresh tangible

DCIT(CC)-8(3), MUMBAI vs. 63 MOONS TECHNOLOGIES LIMITED, MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

reassessment proceedings. Reasons to believe recorded by the ld. Assessing Officer does not advert to any fresh tangible material which has come in his possession after the conclusion of the original assessment proceedings. They only make reference to the Assessment Order for AY 2014-15 and notes to account to the financial statement which in no way constitute fresh tangible