How many judgments cite Micro Ink Ltd. v. ACIT?

61 judgments on BharatTax cite Micro Ink Ltd. v. ACIT (157 ITD 132), spanning 2016 to 2025.

Which sections of the Income Tax Act does Micro Ink Ltd. v. ACIT come up under?

It is most often cited in judgments turning on Section 92B, Section 143(3), Section 147, Section 148, Section 37(1), Section 140A(3).

Micro Ink Ltd. v. ACIT

157 ITD 132Income Tax Appellate Tribunal2016#1881 most cited

What is Micro Ink Ltd. v. ACIT authority for?

Issuance of corporate guarantees does not constitute an international transaction under section 92B, particularly for guarantees provided before the 2012 amendment. Such guarantees are considered shareholder activities or quasi-capital and do not impact enterprise profits, income, losses, or assets.

judgments rely on this decision, according to BharatTax’s citation analysis of 366,418 Indian tax judgments — from 2016 to 2025.

Also referred to as

Micro Ink Ltd. v. ACIT · 157 ITD 132 · section 92B · corporate guarantee · international transaction · shareholder activity · quasi-capital · transfer pricing adjustment · 2012 amendment

Also reported as

88 Taxmann.com 338

Sections most often in play

Section 92B Section 143(3)Section 147 Section 148 Section 37(1)Section 140A(3)Section 14A Section 250

Issues it is cited on

section 92f(v)section 92b(1)section 45(2)section 92f(ii)section 43d corporate guarantee section 92f section 92b section 140a section 92(1)minimum alternate tax project completion method

Judgments citing Micro Ink Ltd. v. ACIT

Siro Clinpharm P. Ltd, Mumbai vs. DCIT Cir 3(3), Mumbai

In the result, appeal of the assessee is allowed

ITA 2618/MUM/2014[2009-10]Status: DisposedITAT Mumbai31 Mar 2016AY 2009-10

Section 143(3)Section 250Section 80ISection 92CSection 92C(2)Section 92C(3)

…a short while, deal with very elaborate and detailed submissions made by learned Departmental Representative, we may begin by pointing out that this issue has been dealt with in detail by decision of a coordinate bench in the case of Micro Ink vs ACIT [(2016) 176 TTJ 8 (Ahd)] wherein the coordinate bench has, inter alia, observed as follows: 21. It is only elementary that the determination of arm's length price, under the scheme of the international transfer pricing set out in the Income-tax Act, 1961, can only be done in respect of an 'international transaction'. Section 92(1) provides that, "(a)ny income arisi…