YAMAHA MOTOR INDIA PVT. LTD. Vs. ACIT
INCOME TAX APPELLATE TRIBUNAL
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B.C.Meena, Member (A) -
(1.) ITA No. 5748/Del/2011, Assessment Year 2007 -08
(2.) THIS is an appeal filed by the assessee challenging the various additions made by the Assessing Officer under section 143(3) read with section 144C of the Income -tax Act, 1961 consequent to the order of the Dispute Resolution Panel dated 08.09.2011. Assessee's shares are owned 100% by Yamaha Motors Company, Japan. Assessee is engaged in manufacturing of Motorcycle and spare parts under "Yamaha" brand name. Assessee had undertaken international transaction with its Associated Enterprises (AE). These transactions were referred to TPO u/s. 92CA(1) of the Act. The grounds raised by the assessee are as under: - -
"1. On the facts and circumstances of the case, the order passed by the learned AO under Section 143(3) read with Section 144C of the Act is bad, both in the eyes of law and on facts.
On the facts and circumstances of the case, the learned AO has erred, both on facts and in law in assessing the income of the assessee at Rs. 25,30,50,980/ - as against loss of Rs. 133,85,69,659/ - declared by the assessee.
(3.) ON the facts and circumstances of the case, the learned AO has erred, both on facts and in law in rejecting the books of accounts of the assessee despite the same being maintained properly and duly audited.;
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