PR COMMISSIONER OF INCOME TAX-5 vs. M/S PAGE INDUSTRIES LTD

In the result, the appeal fails and is hereby dismissed

Bench: ALOK ARADHE,R. NATARAJ

Transfer Pricing Officer has gone into the provision of Section 92A(2) of the Act. It is further submitted that the provisions of sub- Sections (1) and (2) of Section 92A are interlinked and have been read together harmoniously and therefore, the substantial question of law framed in this appeal is required to be answered in favour of the assessee

THE PR. COMMISSIONER OF INCOME TAX vs. M/S EDS ELECTRONICS DATA SYSTEMS INDIA PVT.LTD.

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

Bench: ALOK ARADHE,R. NATARAJ

Transfer Pricing Officer that arithmetic mean of 17.02% of the comparables determined for Arms Length Price computation is erroneous. 7. On the other hand, learned counsel for the assessee submitted that only the revenues from the contract entered into between the assessee and SKF India if at all could be subjected to Arms Length Price test which has been held

THE PR. COMMISSIONER OF INCOME TAX vs. MARLABS INNOVATIONS PVT LTD

The appeal is disposed of with liberty as prayed for by the learned

Bench: S.G.PANDIT,C.M. POONACHA

Transfer Pricing Officer in TPO order whereby the said authority has categorically held that functions of said comparable companies are similar to that of assessee in respect of nature of filed they are involved"? 3. "Whether on the facts and in the circumstances of the case, the Tribunal is right in law in taking different stands on adjustments to comparables

M/S. TOYOTA KIRLOSKAR MOTOR (P) LTD., vs. THE COMMISSIONER OF INCOME TAX

Bench: S.SUJATHA,VINEET KOTHARI

Transfer Pricing Analysis separately for manufacturing segment and trading segment of the Assessee, but the Tribunal vide para-11 of the same order took a view that Date of Judgment 06-08-2018 I.T.A.No.58/2017 M/s. Toyota Kirloskar Motor (P) Ltd. Vs. The Commissioner of Income Tax & Anr. 5/16 on a comprehensive view of the matter, since the trading activity

NOVO NORDISK INDIA PRIVATE LIMITED vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 12 (2

Bench: S.SUJATHA

Transfer Pricing Officer under Section 92CA(1) of the Act for determination of arm’s length price in respect of international transactions - 4 - reported by the petitioner during the subject Assessment year. TPO passed a detailed order under Section 92CA(3) of the Act accepting the arm’s length price reported by the petitioner in respect of its international transactions

PR COMMISSIONER OF INCOME TAX-7 vs. M/S SAMI LABS

Bench: S.SUJATHA,VINEET KOTHARI

Transfer Pricing proceedings had failed to demonstrate that industry capacity was better utilized under similar situations compared to its own and further the Tribunal failed to appreciate that adjustments are to be made in the case of the comparables and not entity which is being analyzed by the assessee and moreover, the assessee had not brought out any information

M/S J K CEMENT WORKS vs. THE STATE OF KARNATAKA

Bench: H.B.PRABHAKARA SASTRY,VINEET KOTHARI

92B of the Union List. The word ‘goods’ appearing in Entry No.54 of the State List has to be understood as defined under Article 366 (12) which defines goods as ‘goods’ includes all materials, commodities and articles; . Thus, the meaning of goods assigned under the General Sales Tax Law or the VAT Law is with reference to the goods which

THE COMMISSIONER OF INCOME TAX vs. PRAVEEN V DODDANAVAR

Bench: SREENIVAS HARISH KUMAR,VINEET KOTHARI

92B of the Union List. The word ‘goods’ appearing in Entry No.54 of the State List has to be understood as defined under Article 366 (12) which defines goods as ‘goods’ includes all materials, commodities and articles; . Thus, the meaning of goods assigned under the General Sales Tax Law or the VAT Law is with reference to the goods which

THE BAILHONGAL URBAN COOPERATIVE BANK LTD vs. THE COMMISSIONER OF INCOME TAX

Bench: S.ABDUL NAZEER,P.S.DINESH KUMAR

92B of the Union List. The word ‘goods’ appearing in Entry No.54 of the State List has to be understood as defined under Article 366 (12) which defines goods as ‘goods’ includes all materials, commodities and articles; . Thus, the meaning of goods assigned under the General Sales Tax Law or the VAT Law is with reference to the goods which