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2018 (12) TMI 133 - HC - Income TaxReopening of assessment u/s 147 - transfer pricing report by EXL India, which has business connection with the petitioner and the company being situated outside India is not liable to pay tax as contemplated under Section 92-C(A) - Held that:- The proceedings initiated under Section 148 of the Act is based on transfer pricing report by EXL India, which has business connection with the petitioner and the company being situated outside India is not liable to pay tax as contemplated under Section 92-C(A) of the Act. Sri Gaurav Mahajan, learned counsel appearing for the respondents prays for and is allowed three weeks' time to file counter affidavit. The petitioner shall have one week thereafter to file rejoinder affidavit. List thereafter before the appropriate Bench. It shall not be treated as part heard or tied up to this Bench. Till the next date of listing, further proceedings pursuant to notice under Section 148 of the Act with regard to assessment year 2011-2012 shall remain stayed.
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