TaxTMI Login
Just a moment...
Press 'Enter' to add multiple search terms. Rules for Better Search
When case Id is present, search is done only for this
of 
of 
No Folders have been created
Are you sure you want to delete "My most important" ?
NOTE:
of of 
All Case Laws
of of All Case Laws
Note
Bookmark
Share
Don't have an account? Register Here
of <h1>Assessee's Appeals Partly Allowed, Transfer Pricing & Capitalization Issues Referred Back</h1> <h3>M/s Plastic Omnium Auto Inergy Manufacturing India Private Limited (Formerly Inergy Automotive Systems Manufacturing India Private Limited) Versus DCIT, Circle-2 Gurgaon</h3> M/s Plastic Omnium Auto Inergy Manufacturing India Private Limited (Formerly Inergy Automotive Systems Manufacturing India Private Limited) Versus DCIT, ... Issues involved:The appeals by Assessee against the common order dated 27/02/2019 of Learned Commissioner of Income Tax (Appeals)-1, Gurgaon for Assessment Years 2012-13, 2013-14, 2014-15, and 2016-17 respectively.AY 2012-13:1. Challenge to the order passed by Ld. CIT(A) u/s 250 of the Act.2. Disallowance of depreciation on international transaction of development expenses.3. Dispute regarding arm's length principle and disallowance of depreciation.4. Interpretation of grounds of appeal and dismissal of appeal.5. Non-adjudication of penalty proceedings u/s 271(1)(c).AY 2013-14:1. Challenge to the order passed by Ld. CIT(A) u/s 250 of the Act.2. Disallowance of depreciation on international transaction of development expenses.3. Dispute regarding arm's length principle and disallowance of depreciation.4. Interpretation of grounds of appeal and dismissal of appeal.5. Non-adjudication of penalty proceedings u/s 271(1)(c) and interest charged u/s 234C.AY 2014-15:1. Challenge to the order passed by Ld. CIT(A) u/s 250 of the Act.2. Disallowance of depreciation on international transaction of development expenses.3. Dispute regarding arm's length principle and disallowance of depreciation.4. Interpretation of grounds of appeal and dismissal of appeal.5. Non-adjudication of interest charged u/s 234A and 234B.AY 2016-17:1. Challenge to the order passed by Ld. CIT(A) u/s 250 of the Act.2. Disallowance of depreciation on international transaction of development expenses.3. Dispute regarding arm's length principle and disallowance of depreciation.4. Interpretation of grounds of appeal and dismissal of appeal.The issues in these appeals are related to the transfer pricing issue arising in the case of the assessee for AY 2011-12. The dispute regarding capitalization of expenses in AY 2011-12 was restored to the file of the Ld. CIT(A) by the Co-ordinate Bench of ITAT, Delhi. The present appeals cannot be decided until the dispute regarding capitalization of expenses is resolved. Therefore, the issues in dispute in the present appeals are restored to the file of the Ld. CIT(A) for fresh order in accordance with law.All grounds of appeal are treated as disposed off in accordance with the directions. For statistical purposes, all the four appeals are treated as partly allowed.
TaxTMI 
TaxTMI 
