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5 results for “transfer pricing”+ Section 10A(4)clear

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Key Topics

Section 114Section 11A3

M/S. STEEL AUTHORITY OF INDIA LTD. (UNIT BHILAI STEEL PLANT) ISPAT BHAWAN . THROUGH ITS SR. MANAGER (F AND A) vs. COMMISSIONER OF CENTRAL EXCISE RAIPUR

C.A. No.-002150-002150 - 2012Supreme Court08 May 2019

Bench: Us. 2. Very Briefly Put, The Question Which We Are Called Upon To Consider & Resolve Is As To Whether Interest Is Payable On The Differential Excise Duty With Retrospective Effect That Become Payable On The Basis Of Escalation Clause Under Section 11Ab Of The Central Excise Act, 1944 (Hereinafter Referred To As “The Act”). 3. In This Batch Of Appeals, We Will Treat C.A. No.2150/2012 As The Leading Case. We Will Refer To The Said Case As The Sail Case. In The Said Case Originally, The Appellant Company Which Is Manufacturer Of Various Products Including Rail

Section 11Section 11A

transfers. 40. It is no doubt true that the accrual of income does not much later depend upon its ascertainment or the accounts cast by assessee. The accounts may be made up at a much later date. That depends upon the convenience of the assessee and also upon the exigencies of the situation. The amount of the income, profits

ASSISTANT COMMISSIONER OF INCOME TAX (EXEMPTIONS) vs. AHMEDABAD URBAN DEVELOPMENT AUTHORITY

C.A. No.-021762-021762 - 2017
Supreme Court
19 Oct 2022

Bench: HON'BLE THE CHIEF JUSTICE

transferred, directly or indirectly, by way of dividend, bonus, or otherwise by way of profit, to persons, who at any time are or had been members of the assessee. The Income Tax Appellate Tribunal (hereafter “ITAT”) after initial remand to the Appellate Commissioner, held that “the primary purpose for which the assessee was established was to promote commerce and trade

SAP LABS INDIA PRIVATE LIMITED vs. INCOME TAX OFFICER CIRCLE 6 (1) (1) BANGALORE

Appeals are allowed

C.A. No.-008463-008463 - 2022Supreme Court19 Apr 2023

Bench: HON'BLE MR. JUSTICE M.R. SHAH

10A to 10E of the Rules, the determination can be said to be perverse which is always subject to the scrutiny by the High Court in an appeal under Section 260A of the Act. 2.4 It is submitted that therefore the view taken by the High Court of Karnataka in the case of Softbrands India (P) Ltd. (supra) is required

ASSTT DIRECTOR OF INCOME TAX I NEW DELHI vs. M/S E FUNDS IT SOLUTION INC

C.A. No.-006082-006082 - 2015Supreme Court24 Oct 2017

Bench: HON'BLE MR. JUSTICE ROHINTON FALI NARIMAN

Section 10A of the Act. Copy of the return was furnished. It was further stated that cost of personnel seconded in India was fully borne by e-Fund India i.e. 100% of the salary paid to the said employees seconded to India were debited to profit and loss accounts. 75% of the salary component was paid abroad by e-Fund

INDUSIND MEDIA AND COMMUNICATIONS LTD. vs. COMMISSIONER OF CUSTOMS NEW DELHI

C.A. No.-002498 - 2018Supreme Court27 Sept 2019

Bench: HON'BLE THE CHIEF JUSTICE

Section 111Section 112Section 114ASection 130ESection 18

10A of the erstwhile Customs Valuation (Determination of Price of Imported Goods) Rules, 1988 and the same should not be redetermined under Rule 9(1) (e) (adding cost of services) of the erstwhile Custom Valuation (Determination of Price of Imported Goods) Rules, 1988; (b) the invoice value of imported goods declared in the (Bill of Entry as Rs.1