2021 (5) TMI 989

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....hri H. Srinivasulu, AR. For the Revenue : Shri R. Dipak, DR. ORDER PER S.S.GODARA, J.M. : This assessee's appeal for AY.2013-14 arises against the DCIT, Circle-17(2), Hyderabad's assessment dated 27-10-2017 framed in furtherance to the Dispute Resolution Panel ('DRP')- 1, Bengaluru's directions dt.01-09-2017 in F.No.367/DRP-1/ BNG/2016-17, involving proceedings u/s.143(3) r.w.s.92CA(3)....

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....d for the sole reason that the same has been made not as per LIBOR rate applicable in case of international transactions but after taking State Bank of India's prime lending rate @14.45% in the Transfer Pricing Officer's (TPO) order and upheld to the extent between 6.5% to 8% as applicable in case of domestic term deposits. 3. Learned CIT-DR's vehement contention is that the TPO as well as the ....

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.... the above terms. 5. Next comes the latter issue of Section 43B disallowance of Rs. 8,11,648/- pertaining to employees provident fund. It is not in dispute that learned lower authorities held that the same had to be deposited before the due date prescribed in the corresponding statute than the due date for filing Section 139(1) return. The Revenue's case in tune thereof relies on Section 36(va)....