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2016 (7) TMI 54 - AT - Income TaxApplicability of transfer pricing provisions - 100% EOU working under STP scheme - whether the transfer pricing provisions cannot be invoked in this case even though admittedly there is no, and there cannot be any, tax avoidance motive in such a situation. - Held that:- the issue is covered against the assessee by the Special Bench decision in the case of AZTEC SOFTWARE AND TECHNOLOGY SERVICES LTD [2007 (7) TMI 50 - ITAT BANGALORE] , yet he prays for constitution for an even larger bench of seven or more Members. Once the issue is covered by a binding judicial precedents, we see no reasons to take any other view of the matter than the view taken by the biding judicial precedents. - preliminary objection raised by the learned counsel rejected - Matter will be heard on merit - Decided against the assessee.
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