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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 191 · Page 1 of 10
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
transfer of property for a price. and adjustment of the rights of the partners in a dissolved firm is not a transfer
transfer of assets notwithstanding the fact that the Company paid a price fixed for the transfer of assets. Under the contract
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
price but only a distribution of the assets of the companies which had gone into voluntary liquidation. Such a transaction does not amount to sale, exchange, relinquishment or transfer
price was paid for the controlling interest which was being transferred along with the shares. HELD : The appeal must be dismissed
In the result we allow these appeals, vacate the answers
price of the goods mentioned therein and transferred those P.D.Os to his buyers after receiving the price fixed 93 for the sale
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
price of the goods covered by the delivery orders and transferred those P.D.Os. to buyers after receiving the price fixed
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
The appeal is dismissed with costs throughout
transfer for a price from one party to another of something that formed part of the enduring asset of one of them
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
