Computation of Deduction under section 10A and depreciation on computer accessories

Last updated: 22 May 2013

Court :
INCOME TAX APPELLATE TRIBUNAL

Brief :
The relevant facts of the case are that in the year under consideration the assessee who is wholly owned subsidiary of Honeywell International Inc. Returned ncome of Rs.15,63,19,080/- by way of filing return on 30th November, 2006. The assessee company is primarily engaged in the business of assembling and manufacturing system sensors. The return was processed under sec.143(1) and thereafter the case was selected for scrutiny by way of issuance of notice under sec. 143(2) on 07.09.2007 followed by another notice under sec. 143(2) sent along with questionnaire under sec. 143(1) on 29.04.2008/08.09.2009. The Assessing Officer observed that in the year under consideration the assessee had undertaken international transactions with its associated enterprises and as the value of international transaction was more than Rs.15 crores after following the procedure laid down in sec. 92CA of the Act the international transaction entered into by the assessee with the associated enterprises was referred to the Transfer Pricing Officer for determining the arm’s length price. The TPO’s report was received wherein no adverse inference was drawn in regard to the transactions with the associated enterprises.

Citation :
Dy. Commissioner of Income-tax, 12(1), New Delhi. (Appellant) Vs. M/s. Honeywell International India Circle (P) Ltd., PlotNo.2A, 1st Floor, Malviya Nagar Corner Market, New Delhi-17. PAN: AABCA7954K. (Respondent)