Axis Mutual Fund Trustee Ltd. Kelkar and Company Limited as comparable for assessee engaged in the business of manufacturing industrial fragrance, flavours and chemical specialities.
RoadMohan Nagar Ghaziabad. In addition, it also offers a wide range of treasury products and services to corporate customers. Press Note No-8 series dated December 16,had waived all the restrictions on payment of royalty under foreign technology collaboration and put the same under automatic route and therefore it held that under these circumstances the assessee could not be permitted to take this stand that since there were no restrictions on payment of royalty by the Government of India, any amount paid by assessee on account of royalty would ipso-facto be its ALP.
Further, it held that the brand equity and intangibles of the company were more than Rs. The Tribunal held that whether a particular expense on services received actually benefits an assessee was not even a consideration for determination of ALP and held that the ALP determination was to be made on the basis of a recognized method and not on the basis of subjective perceptions as done by the TPO.
It noted that the assessee had reimbursed its AE for salary expenses relating to two expatriate employees seconded to it by its AEs, which were paid by AEs outside India for administrative convenience and subsequently reimbursed by the assessee.
The Tribunal held that the assessee engaged in rendering software development services to its AE could not be compared to: The Tribunal held that the assessee engaged in providing contract software development services to its AEs could not be compared to: The Tribunal held that no specific comparables had been considered by the Revenue for the purpose of determining mark-up at 3 percent and that the TPO was incorrect in rejecting the comparables selected by the assessee merely because the AE was not developing the software on its own but was providing software obtained from outside vendors.
Ltd [TSHC BOM -TP] held that Rolta India Ltd could not be accepted as a comparable while conducting the benchmarking exercise of the assesse engaged in providing engineering design services as its financial results pertained to a different accounting period.
To run the plant on full capacity.
It held that it could not be said that the DRP had allowed any relief amounting to Rs. Considering the observations of the High Court with respect to bundling of transactions, it observed that the essence of the judgment was that the two international transactions of Distribution and AMP was to be examined as per transfer pricing provisions, but on an aggregate basis and clarified that the Distribution and AMP expenses, were being aggregated only for ALP determination purposes, and the same did not take away the separate character of the AMP transaction.
Grohe India Private Ltd. The Tribunal, noting the contention of the Revenue that by diverting the borrowed funds outside India, the assessee was diverting the taxable profit outside the jurisdiction, observed that the CIT A had not examined whether the advance made to foreign companies had resulted in shifting of profits.
Joined Balrampur Group on 27 th. Liability products including current accounts, certificates and deposits and time deposits are also offered to large and mid-corporate segments. GM Power Plant Responsibilities: It further held that the assessee should have submitted detailed reasons with particular reference to the availability of raw materials, man power, machinery, capital resources, which have influenced the utilization of maximum capacity and for non-utilization of the installed capacity.
Ltd and the New India Assurance Co.
The Tribunal deleted the TP adjustment with respect to the payment of intra-group management services made by the assessee to its AEs. Ltd [TS ITAT TP], held that when the assessee had provided the guarantee in the course of its stewardship activities for its subsidiaries, it would not constitute an international transaction, and, as such, no ALP adjustment could be made in respect of the same.
International Business[ edit ] The Bank has nine international offices with branches at Singapore, Hong Kong, Dubai at the DIFCShanghai,  Colombo and representative offices at Dhaka, Dubai and Abu Dhabi, which focus on corporate lending, trade finance, syndication, investment banking and liability businesses.
Through the Representative Office at Dhaka. The assessee had provided management services to its AEs to the tune of Rs. RoadMohan Nagar Ghaziabad. Viney is large scale manufacturing of Wire Harness and Automotive parts. To run the plant on full capacity. The assessee filed a writ Petition which was allowed by the High Court.
Thomas Phelps referred to stocks which the potential to give x the investment made in them. Travel Security Services India Pvt. Kelkar and Company Limited as comparable for assessee engaged in the business of manufacturing industrial fragrance, flavours and chemical specialities.
Further, it stated that it was the choice of the assessee as to whether to file an objection before the DRP or to pursue the normal channel of filing appeal against the assessment order before the ld.
The digest will prove invaluable to all practitioners of taxation law. It noted that the assessee had reimbursed its AE for salary expenses relating to two expatriate employees seconded to it by its AEs, which were paid by AEs outside India for administrative convenience and subsequently reimbursed by the assessee.
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The Digest comprises of all the important judgements dealing with transfer pricing, international taxes and domestic taxation laws.
A brief head note is given for each case.Financial statement analysis of maruti suzuki company ltd