Pyramid Delhi High Court order (W.P.(C) 5198/2019 and ITA 1289/2018 )

Delhi High Court admitted the appeal on the issue of inclusion or exclusion of one comparable which in view of the Court constituted a ‘substantial question of law’ and remanded back the matter to the Transfer Pricing Officer with specific directions in favour of client. Delhi High Court held that the Tribunal had erred in not taking into account evidence placed by assessee on record. Rice ITAT Judgment

D Diamond order dated 18.1.19

High Court dismissed the appeal by Department on the basis of assessee’s arguments which principally revolved around the low tax effect of department’s appeal. Rice ITAT Judgment

Renu Creation Delhi ITAT

Based on the arguments presented by Amicus, tax tribunal quashed the levy of penalty (u/s 271(1)(c) of the Income-tax Act, 1961) imposed by lower authorities. Rice ITAT Judgment

De Diamond ITAT Order (ITA 2355/2014)

The fundamental issue was whether manufacturing and trading constituted same or separate business. Keeping in view arguments based on facts and judicial precedents, Tribunal ruled that manufacturing was merely an extension of trading business as there was unity in command and control, single set of audited financial statements, common product and customer for the trading and manufacturing activity. Hence, all expenses incurred in setting up of manufacturing unit were to be allowed even if there were no sales from manufacturing activity and different business segments had been drawn up for Transfer Pricing Benchmarking.

De Diamond Judgment

RT Paper Delhi High Court (ITA 325/2013)

Amicus – Advocates & Solicitors successfully acted as the legal/ arguing counsel for the Company securing tax relief from Delhi High Court in a corporate tax matter involving incorrect disallowance of loss.

Rice ITAT Judgment