Veer Gems v. ACIT & Anr.

351 ITR 35High Court2013#14074 most cited
7

judgments rely on this decision, according to BharatTax’s citation analysis of 350,364 Indian tax judgments — from 2015 to 2019.

Judgments citing Veer Gems v. ACIT & Anr.

M/S. Sava Healthcare Ltd, Pune vs. Assistant Commissioner of Income Tax, Pune

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

ITA 1067/PUN/2017[2012-13]Status: DisposedITAT Pune27 Jun 2019AY 2012-13

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)

…Sony India (P.) Ltd. Vs. CBDT & Anr. (supra) and the Hon’ble Bombay High Court in the case of Vodafone India Services Pvt. Ltd. (supra). The panel had placed reliance on the ratio laid down by the Hon’ble Gujarat High Court in Veer Gems Vs. ACIT & Anr. (2013) 351 ITR 35 (Guj). The Hon’ble Bombay High Court vide paras 35 and 36 have held that the decisions which were rendered in the context of section 92CA(4) of the Act as existing prior to 2007 cannot be applied, post- amendment of 2007, wherein section 92CA(4) of the Act was amended. Further, the Hon’ble High Court did not find favour with the decision in Veer G…

M/S. Sava Healthcare Ltd, Pune vs. Assistant Commissioner of Income Tax, Pune

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

ITA 1066/PUN/2017[2011-12]Status: DisposedITAT Pune27 Jun 2019AY 2011-12

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)

…Sony India (P.) Ltd. Vs. CBDT & Anr. (supra) and the Hon’ble Bombay High Court in the case of Vodafone India Services Pvt. Ltd. (supra). The panel had placed reliance on the ratio laid down by the Hon’ble Gujarat High Court in Veer Gems Vs. ACIT & Anr. (2013) 351 ITR 35 (Guj). The Hon’ble Bombay High Court vide paras 35 and 36 have held that the decisions which were rendered in the context of section 92CA(4) of the Act as existing prior to 2007 cannot be applied, post- amendment of 2007, wherein section 92CA(4) of the Act was amended. Further, the Hon’ble High Court did not find favour with the decision in Veer G…

M/S. Sava Healthcare Ltd, Pune vs. Assistant Commissioner of Income Tax, Pune

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

ITA 1065/PUN/2017[2010-11]Status: DisposedITAT Pune27 Jun 2019AY 2010-11

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)

…Sony India (P.) Ltd. Vs. CBDT & Anr. (supra) and the Hon’ble Bombay High Court in the case of Vodafone India Services Pvt. Ltd. (supra). The panel had placed reliance on the ratio laid down by the Hon’ble Gujarat High Court in Veer Gems Vs. ACIT & Anr. (2013) 351 ITR 35 (Guj). The Hon’ble Bombay High Court vide paras 35 and 36 have held that the decisions which were rendered in the context of section 92CA(4) of the Act as existing prior to 2007 cannot be applied, post- amendment of 2007, wherein section 92CA(4) of the Act was amended. Further, the Hon’ble High Court did not find favour with the decision in Veer G…

M/S. Sava Healthcare Ltd, Pune vs. Assistant Commissioner of Income Tax, Pune

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

ITA 1064/PUN/2017[2009-10]Status: DisposedITAT Pune27 Jun 2019AY 2009-10

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)

…Sony India (P.) Ltd. Vs. CBDT & Anr. (supra) and the Hon’ble Bombay High Court in the case of Vodafone India Services Pvt. Ltd. (supra). The panel had placed reliance on the ratio laid down by the Hon’ble Gujarat High Court in Veer Gems Vs. ACIT & Anr. (2013) 351 ITR 35 (Guj). The Hon’ble Bombay High Court vide paras 35 and 36 have held that the decisions which were rendered in the context of section 92CA(4) of the Act as existing prior to 2007 cannot be applied, post- amendment of 2007, wherein section 92CA(4) of the Act was amended. Further, the Hon’ble High Court did not find favour with the decision in Veer G…

M/S. Sava Healthcare Ltd, Pune vs. Assistant Commissioner of Income Tax, Pune

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

ITA 1063/PUN/2017[2008-09]Status: DisposedITAT Pune27 Jun 2019AY 2008-09

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)

…Sony India (P.) Ltd. Vs. CBDT & Anr. (supra) and the Hon’ble Bombay High Court in the case of Vodafone India Services Pvt. Ltd. (supra). The panel had placed reliance on the ratio laid down by the Hon’ble Gujarat High Court in Veer Gems Vs. ACIT & Anr. (2013) 351 ITR 35 (Guj). The Hon’ble Bombay High Court vide paras 35 and 36 have held that the decisions which were rendered in the context of section 92CA(4) of the Act as existing prior to 2007 cannot be applied, post- amendment of 2007, wherein section 92CA(4) of the Act was amended. Further, the Hon’ble High Court did not find favour with the decision in Veer G…

M/S. Sava Healthcare Ltd, Pune vs. Assistant Commissioner of Income Tax, Pune

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

ITA 1062/PUN/2017[2007-08]Status: DisposedITAT Pune27 Jun 2019AY 2007-08

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)

…Sony India (P.) Ltd. Vs. CBDT & Anr. (supra) and the Hon’ble Bombay High Court in the case of Vodafone India Services Pvt. Ltd. (supra). The panel had placed reliance on the ratio laid down by the Hon’ble Gujarat High Court in Veer Gems Vs. ACIT & Anr. (2013) 351 ITR 35 (Guj). The Hon’ble Bombay High Court vide paras 35 and 36 have held that the decisions which were rendered in the context of section 92CA(4) of the Act as existing prior to 2007 cannot be applied, post- amendment of 2007, wherein section 92CA(4) of the Act was amended. Further, the Hon’ble High Court did not find favour with the decision in Veer G…

(Now known as Sony India Limited)

ITA/16/2014HC Delhi16 Mar 2015

…to Section 92CA of the Act, the decision of the Delhi High Court in the case of Commissioner of Income Tax versus Amadeus India Pvt. Ltd. [2013] 351 ITR 92 (Del) and of the Gujarat High Court in Veer Gems versus Assistant Commissioner of Income Tax [2013] 351 ITR 35 (Guj) would no longer be applicable as the ratio of the said decisions reflects the position of the statute before enactment of Sub- Section (2B) with retrospective effect. 50. With the aforesaid observations, we decide the first substantial question of law in abstract without reference to the facts as a legal proposition, in favour of the…

Veer Gems v. ACIT & Anr. (351 ITR 35) — Cited in 7 Judgments | BharatTax