2020 (2) TMI 1708

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....eera Malhotra, CIT (D.R). ORDER PER SHRI PAVAN KUMAR GADALE, JM : The assessee has filed an appeal against the order of Commissioner of Income Tax (Appeals)-11, Bangalore passed under Section 143(3) r.w.s. 144C and 250 of the Income Tax Act, 1961 ('the Act'). 2. The assessee has raised the only ground of appeal: 3. The assessee company is in the business of promotion of infrastructu....

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....th the Transfer Pricing Adjustments, made disallowance under Section 14A of the act and unamortized amounts claimed and Finally Assessed the total income of Rs.1,67,87,08,248 and passed the order under Section 143(3) r.w.s. 144C of the Act dt.15.12.2017. Aggrieved by the order, the assessee has filed an appeal with the CIT(Appeals). The CIT(Appeals) on the disputed issue considered the submissions....

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.... Representative that there is no requirement of ALP adjustment on this issue, as the AE is permitted to utilize its non-fund based limits, which is in the nature of shareholders operations and on commercial expediency,and prayed for allowing the appeal. Contra, the learned Departmental Representative supported the orders of CIT (Appeals). 5. We heard the rival contentions and perused the material....