How many judgments cite 16. In Nokia India (P) Ltd. v. Dy. CIT?

21 judgments on BharatTax cite 16. In Nokia India (P) Ltd. v. Dy. CIT (153 ITD 508), spanning 2016 to 2025.

Which sections of the Income Tax Act does 16. In Nokia India (P) Ltd. v. Dy. CIT come up under?

It is most often cited in judgments turning on Section 143(3), Section 270A, Section 274, Section 92B, Section 92C, Section 92CA(4).

16. In Nokia India (P) Ltd. v. Dy. CIT

153 ITD 508High Court2015#5595 most cited

What is 16. In Nokia India (P) Ltd. v. Dy. CIT authority for?

Incurring high advertisement and marketing expenses does not preclude the use of the Resale Price Method (RPM) for determining the Arm's Length Price (ALP) under transfer pricing provisions. The ratio of related party transactions (RPTs) calculation requires careful consideration of the numerator and denominator to accurately reflect transactions with associated enterprises.

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2016 to 2025.

Also referred to as

Nokia India · 153 ITD 508 · 52 Taxmann.com 492 · advertisement marketing expenses · resale price method · RPM · arm's length price · ALP · related party transactions · RPT · transactional net margin method · TNMM

Also reported as

52 Taxmann.com 492

Sections most often in play

Section 143(3)Section 270A Section 274 Section 92B Section 92C Section 92CA(4)Section 92D

Issues it is cited on

resale price method tested party related party transaction working capital adjustment transactional net margin method benchmarking analysis comparable companies most appropriate method intangible assets section 92ca(3)arm's length price tnmm

Judgments citing 16. In Nokia India (P) Ltd. v. Dy. CIT

Aditya Birla Minacs Bpo P.Ltd, Mumbai vs. ITO 14(1)(1), Mumbai

In the result, appeal is partly allowed

ITA 566/MUM/2015[2010-11]Status: DisposedITAT Mumbai18 Oct 2016AY 2010-11

Bench: Shri Saktijit Dey & Shri Ramit Kochar

For Appellant: Shri Yogesh TharFor Respondent: Shri N.K. Chand

…parable if the RPT in relation to international transaction does not exceed the threshold limit of 25%. For such proposition ld. authorised representative relied upon the decision of the ITAT Delhi Bench in case of Nokia India Private Limited private limited (153 ITD 508). 14. The learned departmental representative submitted, for computing RPT the transaction of the company as a whole should be taken and it cannot be restricted to international transaction only. 15. Having considered the submissions of the parties and perused the materials on record in the light of decision relied upon. We are of the considere…