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Analysis of Hyundai Rotem Vs ACIT case by ITAT Delhi on tax assessments, time limits under Section 144C, and procedural compliance for international taxation cases.
The application preferred by the petitioner for recall of the said order was also rejected by the Supreme Court vide order dated 25.10.2019. It is thereafter that petitioner-assessee preferred a review petition.
ITAT Bangalore held that when the reasons supplied to the assessee and the reasons supplied before higher forum is not verbatim same, it cannot sustain the validity of reopening of assessment under section 147 of the Income Tax Act.
The controversy in the present appeal relates to inclusion of an entity named E4e Healthcare Business Services Private Limited, as a comparable entity for benchmarking the international transaction of provision of IT-enabled services.
ITAT Mumbai held that GST/service tax which is collected by the assessee from its customers and paid to the Government do not form part of the receipts for computation of income as per section 44BB of the Income Tax Act.
ITAT Mumbai found DRP’s rejection of objections unjustified, remitting the Dresser-Rand case back to the AO for proper adjudication on Transfer Pricing issues.
TPO proposed transfer pricing adjustments of INR 1,03,26,939/-. According to TPO, appellant had advance funds to its AE [i.e. Golden Harvest Middle East (FZC)] under the grab of share application money and there was inordinate delay in allotment of shares.
ITAT Ahmedabad held that the TP assessment carried out by the TPO proceeded on the basis of incorrect appreciation of nature of services availed by the assessee from its AE. Thus, issue of determination of ALP of transactions with AE restored back to TPO.
The failure of assessee to make the requisite disclosures in Schedule D would neither detract from the relief which had been accorded by AO nor change the factum of carry forward and set off as forming part of the assessment order.
The Revenue has filed the present appeal under Section 260A the Income Tax Act, 1961 impugning an order dated 05.01.2024 passed by the Income Tax Appellate Tribunal in ITA No.185/Del/2023 in respect of the assessment year 2013-14.
