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| The Tax Publishers2020 TaxPub(DT) 0214 (Mum-Trib) INCOME TAX ACT, 1961
Section 92CA
TPO dealt with the issue in detail and thereafter recorded an unequivocal finding in detail that transactions claimed by assessee were bogus and were shown in books of account without actually executing any documents taking delivery of goods, etc. Even assessee had shown an earlier date of purchase in its invoice copy as against date of original buyer which was much after the date of purchases shown by assessee. Accordingly, TPO was justified in treating SDT as bogus.
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Transfer pricing - Determination of ALP - Specified domestic transactions - Transactions found to be bogus
Assessee entered into specified domestic transactions (SDT) of purchase of guar seed and crude oil, etc., with its AE. TPO determined ALP thereof at NIL by treating specified domestic transactions (SDT). Assessee challenged this on the ground that TPO exceeded his jurisdiction by characterizing SDT as bogus transactions without undertaking any benchmarking/functional analysis of the same.Held: TPO dealt with the issue in detail and thereafter recorded an unequivocal finding in detail that transactions claimed by assessee were bogus and were shown in books of account without actually executing any documents taking delivery of goods, etc. Even assessee had shown an earlier date of purchase in its invoice copy as against date of original buyer which was much after the date of purchases shown by assessee. Accordingly, TPO was justified in treating SDT as bogus.
REFERRED :
FAVOUR : Against the assessee.
A.Y. :
IN THE ITAT, MUMBAI BENCH
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