PR COMMISSIONER OF vs. M/S SOFTBRANDS INDIA

Bench: S.SUJATHA,VINEET KOTHARI

transfer pricing proceedings, the TPO had selected M/s. HMT Limited as one of the comparables on functional similarity, but while determining the ALP, he had not included M/s. HMT limited as a comparable. The learned Tribunal held: “7.3 We heard the rival submissions and perused the material placed on record. M/s. HMT Ltd., is in the segment of manufacturing

PRINCIPAL COMMISSIONER OF INCOME TAX - 6 vs. M/S. SAMSUNG R & D INSTITUTE BANGALORE PVT LTD

In the result, we do not find any merit in this

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 92-CA of the Act by making an adjustment in respect of software development services. The Assessing Officer thereafter passed an order of assessment incorporating the transfer pricing adjustment. The assessee thereupon filed an appeal before the Commissioner of Income Tax (Appeals) in which selection of Infosys Ltd. as comparable was challenged. The Commissioner of Income Tax (Appeals

THE MANGALORE ELECTRICITY SUPPLY COMPANY LTD., vs. SRI A CHANDRASEKHAR

Bench: G.NARENDAR,P.N.DESAI

price fixed under any law, etc. 29. Deficiency of service is defined under Section 2(1)(g) of the Consumer Protection Act, 1986 in the following manner: “2. (1)(g) ‘deficiency’ means any fault, imperfection, shortcoming or inadequacy in the quality, nature and manner of performance which is required to be maintained by or under any law for the time

THE COMMISSIONER OF INCOME TAX vs. M/S GENISYS INTERGRATING SYSTEMS

Bench: S.SUJATHA,VINEET KOTHARI

Transfer of Shares in Tax Havens (like in the case of Vodafone etc.), if based on relevant facts, such substantial questions of law could be raised before the High Court under Section 260-A of the Act, the Courts could have embarked upon such exercise of framing and answering such substantial question of law. On the other hand, the appeals

PR.COMMISSIONER OF INCOMETAX-2 vs. M/S.EYGBS (INDIA) PVT LTD

Bench: CHIEF JUSTICE,C M JOSHI

58,819/- for AY 2015-16 and ₹62,67,14,829/- for AY 2016-17, under Section 10AA of the Act. In addition, the Assessee had also claimed deduction under Chapter VI-A of the Act. Immediately after filing its original return for AY 2015-16, the Assessee had filed a revised return voluntarily declaring transfer pricing

THE COMMISSIONER OF INCOME TAX vs. M/S FIRST ADVANTAGE OFFSHORE SERVICES PVT LTD

Bench: S.SUJATHA,VINEET KOTHARI

Transfer of Shares in Tax Havens (like in the case of Vodafone etc.), if based on relevant facts, such substantial questions of law could be raised before the High Court under Section 260-A of the Act, the Courts could have embarked upon such exercise of framing and answering such substantial question of law. On Date of Judgment

COMMISSIONER OF INCOME TAX vs. SRI.M.R.JANAKIRAM (HUF)

The appeal is allowed

Bench: ARAVIND KUMAR,E.S.INDIRESH

price of the said land and buy the scheduled property situated in 6.3 acres, immediately. 19. Prayer was sought for a direction to the Official Liquidator to sell the said 6.3 acres of schedule property wherein the Institution of the KIAMS is situated by accepting the amount stated therein. 20. Company Court vide order dated 30.09.2008 took note

PR. COMMISSIONER OF INCOME TAX-4 vs. M/S. KSHEMA TECHNOLOGIES LIMITED

Bench: S.SUJATHA,VINEET KOTHARI

Transfer of Shares in Tax Havens (like in the case of Vodafone etc.), if based on relevant facts, such substantial questions of law could be raised before the High Court under Section 260-A of the Act, the Courts could have embarked upon such exercise of framing and answering such substantial question of law. On the other hand, the appeals

THE COMMISSIONER OF INCOME TAX vs. M/S KARNATAKA CO-OPERATIVE MILK PRODUCERS

Appeal is dismissed with costs

Bench: The Hon’Ble Mr. Justice N.K.Sudhindrarao R.S.A.No.70/2007

price paid or promised or part-paid and part-promised. Sale how made.— 3Such transfer, in the case of tangible immoveable property of the value of one hundred rupees and upwards, or in the case of a reversion or other intangible thing, can be made only by a registered instrument. 1In the case of tangible immoveable property of a value

THE PR COMMISSIONER OF INCOME TAX vs. M/S ACUSIS SOFTWARE INDIA

Bench: S.SUJATHA,VINEET KOTHARI

Transfer of Shares in Tax Havens (like in the case of Vodafone etc.), if based on relevant facts, such substantial questions of law could be raised before the High Court under Section 260-A of the Act, the Courts could have embarked upon such exercise of framing and answering such substantial question of law. On the other hand, the appeals

PR. COMMISSIONER OF INCOME TAX-2 vs. TOYOTA TSUSHO INDIA PRIVATE LIMITED

Bench: CHIEF JUSTICE,C M JOSHI

transfer pricing adjustment at `25,23,76,521/- in the trading segment. 6. In so far as manufacturing segment is concerned, the learned TPO determined the arms length PLI at 3.45% and accordingly made in adjustment of `6,02,89,351/- for the manufacturing segment

THE COMMISSIONER OF INCOME-TAX vs. M/S. CURAM SOFTWARE INTERNATIONAL

Bench: S.SUJATHA,VINEET KOTHARI

Transfer of Shares in Tax Havens (like in the case of Vodafone etc.), if based on relevant facts, such substantial questions of law could be raised before the High Court under Section 260-A of the Act, the Courts could have embarked upon such exercise of framing and answering such substantial question of law. On the other hand, the appeals

THE COMMISSIONER OF INCOME TAX vs. M/S 24/7 CUSTOMER .COM PVT. LTD.

Bench: S.SUJATHA,VINEET KOTHARI

Transfer of Shares in Tax Havens (like in the case of Vodafone etc.), if based on relevant facts, such substantial questions of law could be raised before the High Court under Section 260-A of the Act, the Courts could have embarked upon such exercise of framing and answering such substantial question of law. On the other hand, the appeals

COMMISSIONER OF INCOME TAX vs. TNT INDIA PRIVATE LIMITED

Bench: S.SUJATHA,VINEET KOTHARI

Transfer of Shares in Tax Havens (like in the case of Vodafone etc.), if based on relevant facts, such substantial questions of law could be raised before the High Court under Section 260-A of the Act, the Courts could have embarked upon such exercise of framing and answering such substantial question of law. On the other hand, the appeals

COMMISSIONER OF INCOME TAX-III, vs. M/S SAP LABS INDIA PVT LTD

Bench: S.SUJATHA,VINEET KOTHARI

Transfer of Shares in Tax Havens (like in the case of Vodafone etc.), if based on relevant facts, such substantial questions of law could be raised before the High Court under Section 260-A of the Act, the Courts could have embarked upon such exercise of framing and answering such substantial question of law. On the other hand, the appeals

THE COMMISSIONER OF INCOME-TAX vs. DR. PRADEEP KUMAR

Bench: RAVI MALIMATH,N.KUMAR

Transfer of Shares in Tax Havens (like in the case of Vodafone etc.), if based on relevant facts, such substantial questions of law could be raised before the High Court under Section 260-A of the Act, the Courts could have embarked upon such exercise of framing and answering such substantial question of law. On the other hand, the appeals

PR.COMMISSIONER OF vs. M/S TRIANZ HOLDINGS PVT LTD

Bench: S.SUJATHA,VINEET KOTHARI

Transfer of Shares in Tax Havens (like in the case of Vodafone etc.), if based on relevant facts, such substantial questions of law could be raised before the High Court under Section 260-A of the Act, the Courts could have embarked upon such exercise of framing and answering such substantial question of law. On the other hand, the appeals

THE PR COMMISSIONER OF INCOME TAX CIT(A) vs. M/S GENISYS INFORMATION

Bench: S.SUJATHA,VINEET KOTHARI

Transfer of Shares in Tax Havens (like in the case of Vodafone etc.), if based on relevant facts, such substantial questions of law could be raised before the High Court under Section 260-A of the Act, the Courts could have embarked upon such exercise of framing and answering such substantial question of law. On the other hand, the appeals