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2011 (6) TMI 392 - AT - Income TaxArm's length price - case was referred to determine the arm's length price in relation to the international transactions entered into by the assessee under section 92CA of the Act to the Transfer Pricing Officer (TPO) who, after much deliberation, passed an order under section 92CA of the Act. order served on the assessee contained variation to the returned income such as re-determination of arm's length price (ALP) on certain international transactions entered into by the assessee - foreign exchange gain needs to be considered as being operating in nature while determining arm's length price Deduction under section 10A - telecommunication charges, insurance charges and expenses incurred in foreign currency not excluded from export turnover in computing deduction under section 10A - assessee's contention was that the expenses claimed were not recovered from the customers and also did not form part of export turnover as the assessee was not engaged in providing technical services outside India interest levied under section 234B and 234D of the Act - ground not maintainable as charging of interest under section 234B of the Act is mandatory and consequential in nature. With regard to charging of interest under section 234D of the Act, {ITO v. Ekta Promoters (P.) Ltd.} Held that:- the levy of interest under section 234D is purely a legal ground and chargeable, ground goes against the assessee
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