![]() ![]() The Tribunal remitted the issue relating to existence of international transaction of AMP expenses incurred by the assessee to the file of the TPO for fresh consideration considering the assessee’s reliance on the decision of the Court in Maruti Suzuki which was not available before the TPO. vs.DCIT 76 63 (Chennai – Trib.) (IT APPEAL NO. The Tribunal held that where business relations between assessee and entities were so insignificant that export sales made to them were less than 5 per cent of its entire sales and there was no element of de facto control they could not be treated as AEs under section 92A. ![]() International transactions/ Associated Enterpriseġ. The Digests for the earlier periods are available hereĪ. A brief head note is given for each case. The Digest comprises of all the important judgements dealing with transfer pricing, international taxes and domestic taxation laws. Link to download this article in pdf format is at the bottom ![]()
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