2011 (8) TMI 1391

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.... Shri M. Fahad Khalid, CA For the Respondent : Shri N.K. Chand, Senior DR ORDER PER B.C. MEENA, ACCOUNTANT MEMBER: This appeal filed by the assessee arises out of the order of the assessing officer passed u/s 143(3) read with section 144C of the Income-tax Act dated 09.08.2010. 2. During the year under consideration, the assessee company was engaged in the business of specialty phar....

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....ength Price of the International transactions. The assessee could not justify the filters applied by it and the TPO has carried out a fresh search and applied logical filters to arrive at a comparable on the basis of the same he has computed OP / OC at 19.60%. In the matter of charging of interest @ 6% on the loan of Rs. 46.37 crores from its AE, the assessee could not disclose the details of CUP.....

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....ssing Officer has disallowed Rs. 21,48,564/- being the provision for doubtful / bad debts. The Assessing Officer has observed that vide provisions of Finance Act, 2009 as inserted in clause (i) to Explanation -I of Section 1l5JB (applicable w.e.f. 01.04.2001 retrospectively), the provisions cannot be claimed against the book profit for the purpose of arriving at the income for taxation u/s 115JB o....