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2010 (3) TMI 894 - ITAT MUMBAIRejection of accounts - assessee-company is a non-resident company established in USA and operates its branch office from India - business of distribution of films and has derived income by way of distributing films and advertising accessories and trailers – claim of the assessee is that the said profit has been shown as per books of account regularly maintained by it and the Assessing Officer without examining the books of account rejected the same and applied net rate of profit at 25 per cent of gross film rental as per Boards letter - Held that:- Assessing Officer had no ground to reject books of account within meaning of section 145(3) and, thus, he was required to calculate income as per books of account by applying section 145(1) – matter remanded back to AO Transfer pricing - Reference to transfer Pricing Officer – Assessing Officer referred matter to TPO under section 92CA(1) who vide order under section 92CA(3) directed that certain amount was required to be added to income of assessee - Assessing Officer made addition – Held that:- No opportunity has been provided by the Assessing Officer for final determination of income under sub-section (4) of section 92C read with sub-section (4) of section 92CA of the Act – matter remanded to AO
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