Supreme Court · [2019] 10 S.C.R. 133 · Decided 13 August 2018

The Principal Commissioner of Income TAX-4, Mumbai v. M/S. S.G. Asia Holdings

Court
Supreme Court of India
Citation
[2019] 10 S.C.R. 133
Case number
CIVIL APPEAL No. 6144/2019
Decided
13 August 2018
Bench
UDAY UMESH LALIT, VINEET SARAN (2-judge bench)
Outcome
Appeal(s) allowed
Case type
Civil
Acts & sections cited
Income Tax Act Section 92, 143(3)

Headnote

Income Tax Act, 1961: s.92 - Transfer Pricing Adjustment - Respondent received certain amount of brokerage from its parent company - During the assessment proceedings, respondent was directed to furnish details about the parent company and the rate of brokerage - According to the Assessing Officer, the brokerage charged by the respondent was only 0.05% which was found to be at a lower rate as compared to the prevalent rates in market - Assessing Officer, therefore, while computing the assessment made an addition of Rs.2,89,82,746/- under

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