Comparable - Judgment Search Results

Hindustan Aeronautics Limited, Rep. by Its Managing Director Vs. Compa ...

Court: Karnataka

Reported in: ILR2004KAR4268

..... contention neither in the claim statement nor in the reply statement nor in the evidence compare disclosed what were the books that were not returned their value and availability and how ..... books and manuals were returned hal has categorically contended that all books manuals were returned compare being the claimant was therefore bound to establish by evidence as to what were the .....

“....if a Comparative Assessment Made by a Selection Vs. Indian Oil ...

Court: Punjab and Haryana

..... illegal and vitiated due to extraneous considerations it has been held as under if a comparative assessment made by a selection board is vitiated and the appellants decided to scrap the .....

Sony Ericsson Mobile Communications India Pvt. Ltd Vs. Commissioner o ...

Court: Delhi

..... providers it is apparent have the requisite information and data of external comparables to enable comparability analysis of the controlled and uncontrolled transactions with necessary adjustment to obtain ..... would include amp function expenses ii the second step mandates ascertainment of comparables or comparable analysis ita162014 connected matters this would have reference to the method page .....

Chryscapital Investment Advisors (India) Pvt. Ltd. Vs. Deputy Commiss ...

Court: Delhi

..... a persistently loss excluded or eliminated from the making unit cannot list of comparables be considered as a comparable comparability of an uncontrolled transaction with an international transaction has to be measured ..... making unit fuba india ltd as a and therefore it cannot be comparable considered to be a good comparable comparables have to be tested for each year independently the fact that an .....

Sony India (P) Limited Vs. Deputy Commissioner of Income Tax

Court: Income Tax Appellate Tribunal ITAT Delhi

..... identical uncontrolled transaction the arms length price is determined by taking result of a comparable transaction in comparable circumstances and by making suitable adjustments for the differences 26 the first step in ..... no ownership of intangibles various risks assumed etc in the case of taxpayer as compared with other comparables it is by no means an easy job to evaluate the differences for each .....

Sandstone Capital Advisors Pvt Ltd. Vs. the Asst Commr of Income Tax

Court: Income Tax Appellate Tribunal ITAT Mumbai

..... as discussed above deutche asset management india ltd cannot be considered as a good comparable of the assessee for the purpose of determination of alp of the international transactions ..... the international transaction has been entered into therefore it is mandatory for the purpose of comparing the data of an uncontrolled transaction with an international transaction that the same should .....

M/S Avaya India Pvt. Ltd. Vs.acit

Court: Delhi

..... services provided and the functions performed would be factors for considering the comparability of uncontrolled transactions with controlled transactions 30 as indicated above in order ..... tax administrations published in 2010 hereafter oecd guidelines indicates the comparability factors which are the comparability of uncontrolled transactions entities with the controlled transactions entities sub .....

M/S. McKinsey Knowledge Centre India Pvt. Ltd. Vs.pr. Commissioner of ...

Court: Delhi

..... limited and ladderup corporate advisory pvt ltd by applying stringent standards of comparability analysis to comparables selected under the transaction net margin method also referred to as tnmm ..... range of gross margins however the tnmm is even less dependent on product comparability and functional comparability than the traditional transaction methods because net margins are less influenced by .....

Pr Commissioner Of Vs. M/S Softbrands India

Court: Karnataka

..... the revenue authorities or transfer pricing officer and they would introduce some more comparables rejecting the comparables given by the assessee company applying certain filters like the related party transaction ..... qua turnover filter giving a far too wide or narrower range of comparables or even though comparable entities were functionally different entities from the entities in the list of .....

M/S. L.G. Electronics India Private Limited Vs. the Asstt. Commissione ...

Court: Income Tax Appellate Tribunal ITAT Delhi

..... aes then how a finding that the assessee has incurred more amp expenses as compared to the comparables can survive the finding regarding the alleged non routine expenses would not survive then ..... the amount charged is arm s length by reference to gross profit margin in comparable transaction the comparability depends on similarity of the product under cup method 14 before deciding the impugned .....