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12 results for “transfer pricing”+ Section 120(4)(b)clear

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Key Topics

Section 144C6Addition to Income4Section 652Section 1532Section 153(1)2Capital Gains2Penalty2Exemption2Limitation/Time-bar2Transfer Pricing

THE PRINCIPAL COMMISSIONER OF INCOME TAX 4 MUMBAI vs. M/S S.G. ASIA HOLDINGS (INDIA) PVT. LTD

The Appeal is allowed to the aforesaid extent

C.A. No.-006144-006144 - 2019Supreme Court13 Aug 2019

Bench: HON'BLE THE CHIEF JUSTICE

Section 143(3)Section 92

B) The respondent being aggrieved preferred an appeal before the CIT(A)1, who by his order dated 16.02.2009 confirmed the addition made by the Assessing Officer and dismissed the appeal. The matter was carried further by filing ITA No.2399/Mum/2009 before the Tribunal. 1 Commissioner of Income Tax (Appeals) Civil Appeal No. 6144 of 2019 @ SLP(C)No.12126

ASSISTANT COMMISSIONER OF INCOME TAX vs. SHELF DRILLING RON TAPPMEYER LIMITED

The appeals are allowed

C.A. No.-010586-010589 - 2025Supreme Court08 Aug 2025

HON'BLE MRS. JUSTICE B.V. NAGARATHNA

2
Bench:
Section 144CSection 153Section 153(1)Section 44B

section in case of a conflict with what is contained in the non obstante clause as stated above. 83. Further, a non obstante clause has to be distinguished from the expression “subject to” where the latter would convey the idea of a provision yielding place to another provision or other provisions to which it is made subject to. Also

ENGINEERING ANALYSIS CENTRE OF EXCELLENCE PRIVATE LIMITED vs. THE COMMISSIONER OF INCOME TAX

C.A. No.-008733-008734 - 2018Supreme Court02 Mar 2021

Bench: HON'BLE MR. JUSTICE ROHINTON FALI NARIMAN

b. Storage/Network Use - You may also store or install a copy of the SOFTWARE PRODUCT on a storage device, such as a network server, used on to install or run the SOFTWARE PRODUCT on your other COMPUTERS over an internal network: however, you must acquire and run a licence for each separate COMPUTER on or from which the SOFTWARE PRODUCT

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

C.A. No.-021762-021762 - 2017Supreme Court19 Oct 2022

Bench: HON'BLE THE CHIEF JUSTICE

Section 12AA(1) of the IT Act, on 18.05.1979 and is engaged in the activity of promotion of the export of all kind of ready-made garments, knitwear, and garments made of leather, jute and hemp. It does not per se engage in any activity for profit, and its mandate is to ensure that Indian apparel manufacturers, are given forums

THE AUTHORITY FOR ADVANCE RULINGS (INCOME TAX) vs. TIGER GLOBAL INTERNATIONAL II HOLDINGS

C.A. No.-000262-000262 - 2026Supreme Court15 Jan 2026

Bench: HON'BLE MR. JUSTICE R. MAHADEVAN

transfer of the CGP share and not by virtue of various clauses of SPA. In a case like the present one, where the structure has existed for a considerable length of time generating taxable revenues right from 1994 and where the court is satisfied that the transaction satisfies all the parameters of “participation in 66 investment” then in such

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

Transfer Pricing Officer by his order dated 22nd February, 2006, has specifically held that whatever is paid under various agreements between the US companies and the Indian company are on arm’s length pricing and that, this being the case, even if a fixed place PE is found, 15 once arm’s length price is paid, the US companies

DILIP N. SHROFF vs. JOINT COMMNR. OF INCOME TAX, MUMBAI &ANR

The appeal is allowed

C.A. No.-002746-002746 - 2007Supreme Court18 May 2007
For Respondent: Joint Commissioner of Income Tax, Mumbai & Anr

transferred bears to the Cost Inflation Index for the first year in which the asset was held by the assessee or for the year beginning on the 1st day of April, 1981, whichever is later;" "(v) "Cost Inflation Index", in relation to a previous year, means such Index as the Central Government may, having regard to seventy-five per cent

COMMISSIONER OF CUSTOMS (PORT) KOLKATA vs. M/S. STEEL AUTHORITY OF INDIA LTD

The appeal is dismissed

C.A. No.-006398-006398 - 2009Supreme Court27 Apr 2020

Bench: HON'BLE MR. JUSTICE ANIRUDDHA BOSE

transfer of technology under the process license agreement and whatever expenditure was needed to be incurred for dismantling the plant which was sold on “as in where is basis” in the foreign country and making it ready for delivery on board the vessel to be exported to India. The Supreme Court specifically held that apart from this all other services

COMMISSIONER OF GST AND CENTRAL EXCISE vs. M/S CITIBANK N.A

C.A. No.-008228 - 2019Supreme Court09 Dec 2021

Bench: HON'BLE MR. JUSTICE K.M. JOSEPH

Section 35L(1)(b)Section 64(3)Section 65Section 65(10)Section 65(105)Section 65(12)Section 65(7)Section 83

Section 66 B accompanied by the definition of service under Section 65B (44) and the legislature further providing for the negative 80 list of services which stood excluded from the levy of service tax in Section 66 D, the question would only be whether there is any service and whether it is excluded under Section 66 D. The relevant part

K. KRISHNAMURTHY vs. THE DEPUTY COMMISSIONER OF INCOME TAX

Appeal is disposed of with

C.A. No.-002411-002411 - 2025Supreme Court13 Feb 2025

Bench: HON'BLE MR. JUSTICE DIPANKAR DATTA

Section 132Section 139(1)Section 142(1)Section 260A

price from the land procurers, i.e. the Appellant and Mr. Surendra Reddy. As per Clause 10 of this MOU, Rs.10,00,000/- (Rupees Ten lakhs only) was paid to the procurers for arranging facilitation of transfer of land from the landowners to Mr. Hashim Moosa/his nominees. No other payment, except a reimbursement under Clause 11, was contemplated under this

T.T.G.INDUSTRIES, MADRAS vs. COLLECTOR OF CENTRAL EXCISE, RAIPUR

In the result this appeal is allowed and the order of the

C.A. No.-010911-010911 - 1996Supreme Court07 May 2004
For Respondent: Collector of Central Excise, Raipur

price list and thus the demand of duty having been raised beyond the period of six months is barred by limitation. c) for the same reason as in (b), no penalty can be imposed on the appellants". The cross objection filed by the Collector was not pressed. The members of the CEGAT differed in their opinions. While the judicial member

M/S IVRCL. INFRASTRUCTURE & PROJECTS LTD vs. COMMNR. OF CUSTOMS, CHENNAI

The appeal is dismissed with

C.A. No.-005282-005282 - 2004Supreme Court15 Apr 2015
Section 25(1)

Section 25(1) of the Customs Act, certain items were exempted from payment of customs duty and additional duty leviable under the Customs Tariff Act. We are concerned with serial No.217 of this notification which reads as follows: “217. 84 or any other Goods specified in List 11 Nil Nil 38 Chapter required for construction of roads.” The conditions