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The Appeal is allowed to the aforesaid extent
Bench: HON'BLE THE CHIEF JUSTICE
PRICE UNDER SECTION 92 – GUIDELINES TO TRANSFER PRICING OFFICERS AND ASSESSING OFFICERS TO OPERATIONALISE TRANSFER PRICING PROVISIONS AND TO HAVE
The appeals are allowed
Bench: HON'BLE MRS. JUSTICE B.V. NAGARATHNA
Showing 1–20 of 135 · Page 1 of 7
Transfer Pricing Officer, within two months from the end of the month in which such order of the Transfer Pricing
Bench: HON'BLE MR. JUSTICE ROHINTON FALI NARIMAN
pricing adjudication by the Transfer Pricing Officer (TPO, for short) and the Assessing Officer (AO, for short) in the returns
Appeals are allowed
Bench: HON'BLE MR. JUSTICE M.R. SHAH
transfer pricing, the arm’s length price is to be determined taking into consideration the guidelines stipulated under the aforesaid
price method and cost plus method under the transfer pricing in the Income-tax Act, 1961. Role of Interpretative Notes
Appeals are hereby dismissed
transferred to any other business carried on by the assessee, the price charged for such transfer should correspond to the market
price was paid by the customers as ‘consideration’ for these goods i.e. transfer of property of the goods to the customers
Transfer Pricing Officer8 passed an order under Section 92CA (3) determining the Arm’s Length Price of royalty at 3 per cent
In the result, the appeal is dismissed
price once the goods are cleared in packed condition as per requirement of Standards of Weights and Measures Act, 1976. It was admitted that it was only stock transfer
price or an item incidental to the transfer of the goods dealt with by the assessee. According to High Court
Transfer Pricing Adjustment, Capitalization of Licence Fees, 3G Spectrum Fees, Asset Restoration Cost Obligation including the effect of amalgamation of group
price for the transfer of the vehicle since the entire amount was paid as hire. This contention was not accepted
Appeals are dismissed but in
price of developing. Contract for architectural services was stated to be like a contract by a solicitor to give a legal opinion or for a doctor to give a medical diagnosis since the essence of the contract is the experts skill. The learned counsel contended that the transaction between the appellants and their respective foreign collaborators was one for transfer
Bench: HON'BLE MR. JUSTICE J.B. PARDIWALA
transfer. The company paid the price for the redemption of the shares out of its fund to the assessee and the transaction
Appeals stand disposed of in terms of
transfer of goods for a price cannot be subject to service tax. 4.7 It is submitted that it is true
price being paid for the goods, i.e. transfer of advance import licence in favour of the seller by the buyer
transferred as a going concern for slump sale price, in the absence of evidence on record as to how the slump
Bench: HON'BLE MR. JUSTICE SANDEEP MEHTA
price settled in the MoUs. For this purpose, the respondent would be required to negotiate with the original landowners and facilitate the transfer
price declaration under Rule 173-C in regard to the goods transferred to its depot in Surat for sale therefrom
Appeals are dismissed
Bench: HON'BLE MR. JUSTICE ABHAY S. OKA
price or face value. In many cases, Banks hold the same as investments. Whether the Bank has held HMT security as investment or stockintrade will depend on the facts of each case. HTM Securities can be said to be held as an investment (i) if the securities are actually held till maturity and are not transferred
