Hindalco Industries Ltd. vs Addl. CIT
Maintainability of Writ - Alternate remedy-Reference to TPO-The A.O. had made reference to the TPO as per CBDT's Instructions and after taking approval of CIT. There was an alternate remedy u/s 144C and u/s 253 [LexDoc Id : 428688]
HC (Bombay)
2011
Metal One Corpn. vs DDIT
Stay of Demand- Debatable issue-Bona fide dispute - Controversy as to PE-Ay- 2008-09. The assessee was a Japanese Company. It was trading in steel products. It opened a liason office in India which was treated as it’s PE by [LexDoc Id : 424994]
ITAT (Delhi)
2011
Phoenix Mecano India Ltd. vs DCIT
Computation of: ALP-Margin of tolerance - Law applicable-Ay- 2007-08. There was a fall in g. p. rate of about 5% when compared with last year.
The adjustments in ALP were to be made only in regard to [LexDoc Id : 424988]
ITAT (Mumbai)
2011
Kuehne + Nagel (P) Ltd. vs ACIT
ALP- C & F Agent. / C&F Agent & ALP-Comparable instances Rule of consistency-Ay- 06-07. The assessee was an international C&F agent. It did not own trucks, airplanes or such other transportation assets.
The TPO chose cer [LexDoc Id : 424986]