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Case Law Details

Case Name : Sony India Private Limited Vs ACIT (ITAT Delhi)
Related Assessment Year : 202-21
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Sony India Private Limited Vs ACIT (ITAT Delhi)

Assesssee Wins Major TP Relief – ITAT Deletes Royalty, AMP & Stock Valuation Adjustments; Issues Remanded for Non-Speaking DRP Order

Assessee challenged multiple transfer pricing & corporate tax adjustments made in the assessment order passed u/s 143(3) r.w.s. 144C(13)/144B, pursuant to DRP directions. Assessee also sought admission of an additional ground (Ground 29) regarding DRP’s failure to pass a speaking order on comparables & classification of service income. Tribunal admitted the additio

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CA Vijayakumar Shetty qualified in 1994 and in practice since then. Founding partner of Shetty & Co. He is a graduate from St Aloysius College, Mangalore . View Full Profile

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Recorded Sales Cannot Be Taxed Again U/s 68; Additions Based Only on Third-Party Statement Deleted On-Money Addition for Flat Purchase Deleted; Builder’s General Statement Alone Not Enough Bogus Purchase Cases: Only Profit Element Taxable; 4% GP Addition Upheld Assessment on Amalgamated Company Held Void for Lack of Jurisdiction Penalty for Non-Compliance Deleted as Venial Breach Where Assessments Accepted Returned Income View More Published Posts

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