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2006 (11) TMI 135 - Supreme Court
Seizure - hearing given is only in terms of s. 142(3) which is limited only to the findings of the special auditor - order of assessment would be based upon the findings of special auditor subject of ... ...
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2006 (10) TMI 88 - DELHI HIGH COURT
Validity of CBDT’s instruction that Assessing Officer can refer to Transfer Price Officer if transaction value increase more than Rs 5 crore – such instruction are based on correct interpretation of r... ...
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2018 (11) TMI 1106 - ITAT MUMBAI
TPA - Adjustment made to the arm's length price of advertisement, marketing and promotional (AMP) expenditure incurred by the assessee in respect of consumer segment - whether AMP expenditure incurred... ...
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ANTI-PROFITEERING IN GST: CONSTRUCTIVE EVIDENCE MUST
Section 171 of GST law is the most powerful provision to check excessive profiteering resorted to by businesses owing to tax efficiency accruing because of goods and services tax (GST). The Nationa... ...
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2023 (3) TMI 665 - ITAT DELHI
TDS u/s 194I - TDS on common area maintenance charges - payment made to the landlord, other than under the head rent - HELD THAT:- As relying on M/s. Johnson Watch Company Pvt. Ltd. [ 2022 (11) TMI 1... ...
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2015 (10) TMI 1601 - ITAT HYDERABAD
Disallowance of employees' contribution of provident fund under section 36(1)(va) - Held that:- Though it is a fact that the assessee has remitted the employees' contribution to provident fund not wit... ...
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2023 (6) TMI 208 - ITAT DELHI
Short deduction of TDS - TDS at 10% u/s 194I or at 2% u/s 194C - Common Area Maintenance charges (CAM) paid - HELD THAT:- CAM charges paid by the assessee or not for land used or area allotted simpli... ...
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2017 (4) TMI 452 - ITAT DELHI
TPA - AMP expenses to be an international transaction - Held that:- It is a matter of record that the Hon’ble High Court in Sony Ericsson (2015 (3) TMI 580 - DELHI HIGH COURT) has held AMP expenses as... ...
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2016 (7) TMI 910 - ITAT MUMBAI
Disallowance of business expenditure - ratio of personnel cost - nexus between the expenditure incurred and the business of the assessee - only objection of both the authorities is that the assessee w... ...
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2014 (12) TMI 1212 - ITAT MUMBAI
Transfer pricing adjustment - choice of comparable - Held that:- M/s. Artefact Projects Ltd. company is having a very high percentage of related party transaction, it cannot be considered as a compara... ...
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2007 (7) TMI 50 - ITAT BANGALORE
For making adjustments u/s 92C(3)(a) to (d), AO need not required to demonstrate before the assessee - The provision of Sec 40A is not applicable here - Further tribunal decided upto the matter relat... ...
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2020 (12) TMI 487 - NATIONAL ANTI-PROFITEERING AUTHORITY
Profiteering - Restaurant Services - benefit of reduction in the rate of tax not passed on - contravention of the provisions of Section 171 of the CGST Act, 2017 - penalty - HELD THAT:- The Responden... ...
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2022 (11) TMI 1106 - ITAT DELHI
TDS u/s 194I - CAM charges paid by the appellant company considering the common area maintenance charges as part of the rental activity covered u/s 194I and treated the appellant company as assessee i... ...
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2017 (10) TMI 535 - ITAT DELHI
Transfer pricing adjustment towards Advertisement, Marketing and Promotion expenses - Held that:- In light of the non-sustainability of the objections taken by the Ld. AR and following the earlier vie... ...
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2017 (7) TMI 1004 - ITAT DELHI
AMP expenditure treated as international transaction Coming to the case at hand - Held that:- We are of the considered view that when the TPO has determined the AMP expenses to be international transa... ...
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2006 (10) TMI 107 - DELHI High Court
Judge(s) : MADAN B. LOKUR, VIPIN SANGHI. JUDGMENT The judgment of the court was delivered by MADAN B. LOKUR J. -These are two writ petitions raising the same issue and question of law. The chall... ...
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2006 (10) TMI 76 - HIGH COURT, DELHI
Direction for special audit u/s 142(2A) - Article 226 of the constitution cannot be invoked all that is to be consider is whether the decision making process is vitiated - Direction u/s 142(2A) are unexceptionable and valid ... ... ...
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2017 (9) TMI 376 - ITAT DELHI
Transfer pricing adjustment on Advertisement, Marketing and Promotion (AMP) expenses - determination of the existence or otherwise of an international transaction on account of AMP expenses incurred b... ...
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2017 (5) TMI 1367 - ITAT DELHI
Addition on account of transfer pricing adjustment AMP expenses - AR contended that the TPO for the A.Y. 2012-13 in assesse’s own case has not made any transfer pricing adjustment on account of AMP ex... ...
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2017 (5) TMI 1305 - ITAT DELHI
Determining the ALP of AMP expenses - Held that:- We set aside the impugned order and remit the matter to the file of TPO/AO for a fresh determination of the question as to whether there exists an int... ...
