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2018 (12) TMI 608 - SC - Income TaxAddition on account of guarantee commission chargeable to its associated enterprises - tribunal deleted addition - whether the benchmark fixed by the Transfer Pricing Officer (TPO) for the international transaction by considering arm’s length rate of the bank guarantee at 3% under Section 92CA(3) of the Income Tax Act, 1961 was correct? - Held that:- Question No.1 has been rightly decided by the High Court in favour of the Assessee and against the Revenue. The same would, therefore, not require reopening in this appeal. Interest charged u/s 234B - MAT computation - Whether interest was not payable by the assessee/respondent under Section 234B of the Income Tax Act, 1961 on failure to deposit the advance tax in respect of tax payable under Section 115JB? - Held that:- The matter will require an in-depth hearing. List the appeal on the said question i.e. question No.(ii) as per its turn.
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