2019 (11) TMI 1384

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.... A. K. Jasani For the Respondent : Mr. N. C. Mohanty ORDER P.C:- Heard. 2 This Appeal relates to Assessment Year 2011-12. 3 Appellant urges the following questions of law in its Memo of Appeal:- "(1) Whether on the facts and circumstances of the case and in law, the Tribunal was justified in not adjudicating the ground of additional demand of Rs. 10,87,377/- on Dividend ....

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....e to the Assessing Officer for determination of arm's length price on the said receivables, when no transfer pricing adjustment was made by the Assessing Officer/ TPO in the assessment order and there was no issue before the Tribunal for determination of arm's length price on the said transaction? (4) Whether on the facts and circumstances of the case and in law, the Tribunal was justifie....

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....n loans given by the Appellant to Piramal Glass (UK) Ltd. as the same has been given by the Appellant to increase and expand the business of the Appellant? (7) Whether on the facts and circumstances of the case and in law, the Tribunal was justified in holding the arm's length price of interest free loan to M/s. Piramal Glass (UK) Ltd. ought to be computed at the rate of LIBOR + certain m....

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....t transaction, relying on clause 13(e) of the Tax Audit Report which was an inadvertent mistake by the Tax Auditor? (11) Whether on the facts and circumstances of the case and in law, the Tribunal ought to have held that the amount of Rs. 37,12,635/- being gains arising on valuation of foreign currency loan at the end of the year is on capital account and, hence, not chargeable to tax?" ....