Principal Commissioner Of Income Tax 1, New Delhi Vs DCM Shriram Ltd
.... including differences in accounting practices, if any, between the international transaction or the specified domestic transaction and the comparable uncontrolled transactions, or between the enterprises entering into such transactions, which could materially affect the amount of gross profit m ...
Delhi High Court
DCIT Vs Gemalto Digital Security Pvt. Ltd.
.... nsel for the assessee submitted that the order passed by the CIT(A) as per law and assessee provided the accurate details of losses on the basis of the record. The assessee furnished the accurate particulars, so the penalty cannot be imposed on the assessee. It is also submitted that Revenue had ...
Income Tax Appellate Tribunal (Delhi I Bench)
Dabur India Limited Vs DCIT
.... nd that it had to manufacture the products as per the local needs and taste of the public residing in the public area. It is also his submission that in order to penetrate the Bangladesh market, ACCPL adopted its own market strategy and had made alt the efforts for the establishment of 'Dabur na ...
Income Tax Appellate Tribunal (Delhi I Bench)
American Express Services India Ltd Vs DCIT
.... ng and distribution of credit cards and personal loan products of American Express Bank Limited. 4.1 At the outset, ld. Counsel of the assessee prayed for admission of additional evidences and pleaded that the matter may be remanded to AO/TPO for fresh consideration. He submitted that in si ...
Income Tax Appellate Tribunal (Delhi I Bench)
Pr. Commissioner Of Income Tax � 8 Vs M/S Sony India Pvt. Ltd.
.... n submissions, the appellant/revenue has not availed of the opportunity. 13. The submissions advanced by Mr Sanjeev Menon can be, broadly, paraphrased as follows: (i) The “Sony” brand is promoted by the respondent/assessee in India. The respondent/assessee has incurred huge expens ...
Delhi High Court
American Express Services India Ltd. Vs DCIT
.... 2017); judgement of the Hon’ble Bombay High Court in the case of CIT vs. Smt. Kamal C. Mahboobbani, 81 taxmann 311 (Bom)/214 ITR 15 (Bom); judgement of the Hon’ble Delhi High Court in the case of CIT vs. Tax Hundred India Pvt. Ltd., 239 CTR 263; and the judgement of the Hon’ble High Court of Guj ...
Income Tax Appellate Tribunal (Delhi I Bench)
Denso Haryana Pvt. Ltd. Vs DCIT
.... ely different and there is no overlap between them. The cost of intra-group services pertains to services availed from overseas employees of the AE who are specialists in their field and assist all the group companies in the region. These are specialized services provided by Appellant’s AE to al ...
Income Tax Appellate Tribunal (Delhi I Bench)
Sumitomo Corporation India Pvt. Ltd. Vs Assessing Officer, DCIT
.... ssessee has undertaken 1044 transaction with AE and only 112 transaction with non AE and the commission with AE is 1.28%, whereas non AE it is 2.26%. Similarly, the products dealt with AE and non-AE under this segment are quite different and geography involved with AE are Spain, Japan, Italy, Sw ...
Income Tax Appellate Tribunal (Delhi I Bench)
Pr. Commissioner Of Income Tax-4 Vs M/S Hellmann Worldwide Logistics India Pvt. Ltd.
.... e transactions related to import/export of goods/services. Accordingly, vide order dated 31.10.2019 the TPO computed the arm’s length price of the international transactions related to freight charges received on import and export at Rs.3,18,65,395/- as against Rs.9,57,51,817/- which was determi ...
Delhi High Court
GBT India Private Limited Vs ACIT
.... ircumstances of the case and in law, the Ld. AO erred in levying interest under Section 234A and 234B of the Act. 23. That, on the facts and circumstances of the case and in law, the Ld. AO erred in initiating penalty proceedings under Section 271(1)(c) of the Act. Each of the above grounds ...
Income Tax Appellate Tribunal (Delhi I Bench)
Get In Touch With Us
We are here to help. Want to learn more about our services? Please get in touch, we'd love to hear from you!
