0 per cent related party transaction: Difficulty in finding out a comparable having no related party transaction

Case: ADIT vs. Persys Punj Lloyd Jv,¬†Delhi ITAT Outcome: Assessee Facts The Assessee excluded companies that had substantial transaction to the tune of more than 25% with related parties. The Transfer Pricing Officer held that it was an appropriate filter to eliminate the influence of the control transactions.The Commissioner of Income Tax (Appeals) held that … Continue reading 0 per cent related party transaction: Difficulty in finding out a comparable having no related party transaction

Conditions as mentioned in section 92A(1) & 92A(2): Whether mutually inclusive?

Case: Sovereign Safeship Management Pvt. Ltd. vs. The Income Tax Officer Ward 13(2)-2, Mumbai ITAT Outcome: Partial Facts Shri Rajeev Kumar Singh, the director of the Assessee Company after thorough discussions with its former employer, agreed to become a 13% shareholder in a newly floated company named M/s. Sovereign Ship Management Ltd, UK, in June … Continue reading Conditions as mentioned in section 92A(1) & 92A(2): Whether mutually inclusive?