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11 results for “transfer pricing”+ Section 131clear

Sorted by relevance

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Key Topics

Section 144C6Section 806Section 1323Addition to Income3Section 1532Section 153(1)2Section 42Section 4(1)2Section 652Exemption

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

The appeals are allowed

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

Bench: HON'BLE MRS. JUSTICE B.V. NAGARATHNA

Section 144CSection 153Section 153(1)Section 44B

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any foreign company. Further, it is proposed to make consequential amendments— (i) in sub-section (1) of section 131

COMMISSIONER OF CENTAL EXCISE AND SERVICE TAX ROHTAK vs. M/S. MERINO PANEL PRODUCT LTD

C.A. No.-006891 - 2018Supreme Court05 Dec 2022
2
Penalty2
Deduction2

Bench: HON'BLE THE CHIEF JUSTICE

Section 2Section 4Section 4(1)Section 4(1)(a)Section 4(1)(b)Section 4(3)(b)

transfer of goods solely to related parties; iv) The show cause notice by the Revenue sought to assess the value of the goods by relying on Rule 11 of the CEVR, read with Rule 4 and Section 4(1)(a) of the CEA. This was contrary to the CBEC Circular and rendered the notice defective and unenforceable; v) Consequently

PRINCIPAL DIRECTOR OF INCOME TAX (INVESTIGATION) vs. LALJIBHAI KANJIBHAI MANDALIA

The appeal is allowed and the order passed by the High

C.A. No.-004081-004081 - 2022Supreme Court13 Jul 2022

Bench: HON'BLE MR. JUSTICE HEMANT GUPTA

Section 132Section 132(1)Section 143(3)

transferred a sum of Rs. 6 crores on 01.06.2016 and Rs. 4 crores on 21.06.2016 to M/s Goan Recreation Clubs Private Ltd. The assessee secured the loan by way of a mortgage of the property forming part of Survey No. 31/1-A situated in Village Bambolim, Distt. North Goa. It is an admitted fact that the assessee became the Director

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

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

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

transfer to the copy/copies any copyright or other marking on the Software or Documentation. d) not use the Software or Documentation for any other purpose than permitted in this Article 20, License or sell or in any manner alienate or part with its possession. e) not use or transfer the Software and/or the Documentation outside India without the written consent

COMMISSIONER OF CENTRAL EXCISE SERVICE TAX vs. ULTRA TECH CEMENT LTD

Appeal is allowed, judgment of the

C.A. No.-011261-011261 - 2016Supreme Court01 Feb 2018

Bench: HON'BLE MR. JUSTICE A.K. SIKRI

Section 11ASection 75

transfer basis and sells the same in bulk form and packed bags. The assessee during the period from January, 2010 to June, 2010 availed Cenvat Credit of service tax paid on outward transportation of goods through a transport agency from their premises to the customer’s premises. According to the appellant/Revenue, the transport agency service used by the assessee

RAMNATH AND CO. vs. THE COMMISSIONER OF INCOME TAX

C.A. No.-002506-002509 - 2020Supreme Court05 Jun 2020

Bench: HON'BLE MR. JUSTICE DINESH MAHESHWARI

Section 80

131 of 2002 and, in any case, it being a matter of interpretation of statutory language of Section 80-O and its Explanation (iii), 41 the contention on behalf of the appellant about want of challenge to the findings is without substance. Rejoinder submissions on behalf of the appellant 11. The submissions made on behalf of the respondent have been

GENPACT INDIA PRIVATE LIMITED vs. DEPUTY COMMISSIONER OF INCOME TAX

C.A. No.-008945-008945 - 2019Supreme Court22 Nov 2019

Bench: HON'BLE THE CHIEF JUSTICE

Section 115QSection 143(2)Section 77A

transfer of shares of Mauritius resident taxable in that country and under Mauritius tax laws capital gain is totally exempt, entire transaction used to escape the tax net. Thus to plug this loop hole in the statute, Section 115QA is introduced to provide that where shares are bought back at a price higher than the price at which those shares

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

M/S. ESCORTS LTD. vs. COMMNR. OF CENTRAL EXCISE, FARIDABAD

The appeal is allowed accordingly

C.A. No.-006561-006561 - 2004Supreme Court29 Apr 2015

transferred any transmission assemblies to any other person. However, they have been supplying the transmission assembly to their own units at Nagpur and Rudhrapur for manufacturing tractors. (b) It is submitted that this letter can at most lead to a conclusion that the transmission assembly made by M & M is marketable. 50. The show cause notice has placed reliance