Court : Income Tax Appellate Tribunal ITAT
Decided on : Jul-12-2007
Reported in : (2007)107ITD141(Bang.)
..... company engaged in the business of development and export of software. the assessee was also entitled to deduction under section 10a of the income-tax act, 1961 (the act) in respect of the profits and gains derived from export of software. the assessee company filed its return of income for asstt. year 2002- ..... the party in question unless application of such rule is expressly excluded, (v) the assessment proceedings are judicial proceedings in view of section 136 of the act and, therefore, any order of the assessing officer in the course of assessment proceedings cannot be considered on administrative order, (vi) justice is not only ..... shifting out of profits by manipulating prices charged or paid in international transactions, thereby eroding the country's tax base.4. accordingly, legislative changes through finance act, 2001 and 2002 were made. it was provided in section 92(1) that income arising from international transaction between associated enterprises shall be computed having regard .....
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