2015 (2) TMI 981 - ITAT DELHI
Tata McGraw Hill Education Pvt. Ltd. Versus ACIT, Circle 16(1), New Delhi.
Transfer pricing adjustment - international transactions in the `Back office support services segment’ - selection of comparables - Held that:- Accel Transmatic Ltd. (Seg.) - it can be seen from the Annual report of this company has three divisions, ......
2015 (1) TMI 962 - ITAT HYDERABAD
Mr. Anil Bhansali Versis Income Tax Officer, Ward 12(2) Hyderabad.
Reopening of assessment - Assessee filed the return as ‘Resident but not ordinarily Resident’ - SOTP attributable to services rendered in India - value of perquisites as unexplained income - Indo-US DTAA - whether the provisions of the section 5(1) ......
2015 (1) TMI 650 - ITAT PUNE
M/s. Gera Developments Pvt. Ltd. Versus JCIT (OSD), Circle-1(2), Pune
Addition invoking the provisions of section 40(a)(i) - fee for technical services - Held that:- The insistence of the Revenue to say that the amount has been paid in this year and therefore it is covered within the prescription of section 40(a)(i) of ......
2015 (1) TMI 1121 - KERALA HIGH COURT
Pattambi Service Co-operative Bank Ltd. and Others Versus Union of India and anothers
Constitutional validity of section 133(6) of the Income Tax Act, 1961 to the extent the words "enquiry or" have been added thereto, also incorporating "second proviso" - Held that:- The fact that the petitioners' Bank is a society registered unde ......
2014 (12) TMI 174 - ITAT AMRITSAR
Deputy Commissioner of Income Tax Versus M/s. Irfan Carpets
Deletion of additions of creditors – Onus discharged by assessee regarding genuineness of transactions - Held that:- The assessee has declared a better G.P. rate at 6.07% as compared to 3.24% in the preceding year and 3.07% in the year before precedi ......
2014 (11) TMI 796 - ITAT DELHI
Uem India Pvt. Ltd. Versus ACIT, Circle 18(1), New Delhi
Addition of outstanding balance of certain creditors – Failure to comply with notices issued u/s 136(6) – Held that:- AO failed to offer any comment on the evidences filed by the assessee and insisted for sustenance of disallowance on the basis that ......
2014 (12) TMI 57 - ITAT DELHI
Asstt. Commissioner of Income Tax Versus Inlay Marketing Pvt. Ltd.
Validity of order passed u/s 153C/143(3) – Bar of limitation - Held that:- The AO must be prima facie satisfied that the documents etc. belong to the other person than the person searched - such satisfaction has been stated to have been recorded and ......
2014 (12) TMI 804 - ITAT BANGALORE
M/s. Actiance India Private Ltd. Versus The Income Tax Officer, Ward 11(2), Bangalore.
Computation of deduction u/s 10A - Exclusion of expenses on travel exenses in foreign currency – expenses towards telecommunication expenses form export turnover – Held that:- following the decision in CIT v. Tata Elxsi Ltd [2011 (8) TMI 782 - KARNAT ......
2014 (12) TMI 681 - ITAT BANGALORE
FCG Software Services (India) (P.) Ltd. Vresus Income-tax Officer, Ward 11 (2), Bangalore
Export of software development services – Selection of comparables – Functionally dissimilar company - Avani Cincom Technologies Ltd. - Persistent Systems Ltd. - Softsol India Ltd. - Held that:- Following the decision in M/s. 3DPLM Software Solutions ......
2014 (12) TMI 893 - ITAT BANGALORE
M/s. Bearingpoint Property Services Private Limited Versus The Deputy Commissioner of Income Tax, Circle 11(2), Bangalore.
Transfer pricing adjustment – Determination of ALP on international transaction – software development and system integration services rendered to Bearing Point Group and its worldwide customers – Selection of comparable - Avani Cincom Technologies L ......
2014 (8) TMI 122 - ALLAHABAD HIGH COURT
State of UP. And Another Versus The Commissioner, Income Tax And 3 Others
Notice u/s 133(6) – requiring Sub Registrars to furnish information in respect of transactions relating to immovable property of a value between ₹ 5,00,000/- and ₹ 30,00,000/- – Held that:- A meeting had taken place when both the Income T ......
2014 (7) TMI 561 - GUJARAT HIGH COURT
Commissioner of Income Tax Versus MP. Scrap Traders
Unexplained investment in stock - Whether the Tribunal is justified in coming to the conclusion that retraction made by the assessee from the statement u/s 133(A) of the Act is legal and proper – Held that:- The AO solely relied upon the statement of ......
2014 (7) TMI 861 - ITAT MUMBAI
Manohar Manak Alloys P. Ltd. DC. Bothra & Co. Chartered Accountants Versus ACIT 4(2), Mumbai
Proportionate interest disallowed – Interest free loans and advances given to sister concern - Held that:- The assessee has taken a plea that the total interest free funds available to the assessee company are sufficient to make the interest free adv ......
2014 (5) TMI 772 - ITAT DELHI
Cheil India Pvt. Ltd. Versus DCIT, Circle 3(1), New Delhi
Transfer pricing adjustment – Determination of ALP – Held that:- The assessing authority issued notice u/s 133(6) to M/s Magnum Interior P. Ltd. on 28-1-2014 - the party did not furnish any detail except balance confirmation, the AO proceeded to add ......
2014 (5) TMI 397 - ITAT DELHI
Income Tax Officer Versus Shri Sandeep Aggarwal
Disallowance of bogus lorry hire expenses – Failure to produce documents – Information u/s 133(6) of the act cannot called - Held that:- If the broker has not replied to the letter of the AO, no adverse inference can be drawn against the assessee - t ......