the assessee to provide proper and credible evidence. It held that it was open forex market rate a tangible and material information sufficient for the purposes of re-opening of the assessment. As the company was engaged in software development services and products and was also engaged in R D activities and owned Intangibles. Where Assessee converted the stock-in-trade of shares into investments and sold the same at a later stage, the Court held that profit arising from such sale of shares was deemed to be capital gains and not business income, and since the shares were held. Sterlite Industries (India) Ltd TS-278-itat-2017(chny)-TP ITA Nos.318 319/Mds/2008 dated. Vs dcit TS-282-itat-2017(DEL)-TP ITA. Kpmg TS-150-itat-2017(Mum) ITA.2493/Mum/2012. 481 482 of 2005, 694 of 2017, 258 of 2016) Reassessment 116. The Court held that Tribunal failed to consider the reasonableness of the expenditure in relation to the prudent business practice from a fair and reasonable point of view. Accordingly, the Court set aside ccits order and directed the Revenue to decide the application afresh on merits.
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It noted that this issue was referred by AE under India-Japan MAP pursuant to bfc forex cochin which order was passed wherein royalty payment was agreed to be allowable @.15 and that the order giving effect to MAP was passed by the. Further, it considered cbdt Circular. Ltd TS-287-itat-2017(DEL)-TP ITA. The TPO, contended that if the subsidiary was to obtain loan from bank, owing to its lower credit rating, it would have required a guarantee from assessee, and thus worked out effective borrowing rate of assessee.7.e. 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. The Tribunal held that the assessee, engaged in providing travel security services to its AEs could not be compared to: Apitco Ltd as the company was engaged in providing services in the nature of Project report preparation, Technical and economic studies, Feasibility studies, Micro enterprise. Accordingly, it held that the payment made by the assessee towards reimbursement of salary of seconded employees had to be accepted to be at arms length. Noting that the AO had sought to distinguish the facts and circumstances of assessees case with the case of Knorr Bremse, the Court stated that whether such distinction of the facts as done by the first respondent was correct or not, was for the next. Further, the court rejected the contention of the assessee that since the Board itself did not have the jurisdiction u/s 119 of the Act to pass an order of that nature, it had to be inferred that the Commissioner also lacked jurisdiction to direct the. Where the assessee, an Indian member of kpmg International (kpmgi Switzerland, a mutual association, made payment towards reimbursement of cost to kpmgi, (as per the Membership Agreement) to enable it to discharge its function, the Tribunal held that the said payment was not taxable 1). The Tribunal granted the assessee extension of stay of outstanding demand for a period of 3 months or till disposal of appeal, whichever is earlier. Dcit TS-285-itat-2017(DEL)-TP ITA.6828/Del/2015.
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