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14 results for “transfer pricing”+ Section 139(9)clear

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Key Topics

Section 144C6Section 1324Section 143(2)4Addition to Income4Section 11A3Section 473Section 803Deduction3Penalty3Section 260A

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

139 speaks of filing of return of income. Section 143 deals with ‘assessment’ while Section 144 deals with ‘best judgment assessment’. Under Section 144A the Joint Commissioner has the power to issue directions in certain cases while under Section 144BA reference can be made to the Principal Commissioner or Commissioner in certain cases. Section 144C deals with reference to dispute

M/S JINDAL EQUIPMENT LEASING CONSULTANCY SERVICES LTD. vs. COMMISSIONER OF INCOME TAX

Appeals stand disposed of in the aforesaid terms

2
Section 142(1)2
Limitation/Time-bar2
C.A. No.-000152-000152 - 2026Supreme Court09 Jan 2026

Bench: HON'BLE MR. JUSTICE R. MAHADEVAN

Section 143(3)Section 28Section 47

transfer”, but whether the assessee, in consequence of the amalgamation and thereby of its business, has obtained a profit that is real and presently realisable. The well-known real-income principle, as emphasised in E.D. Sassoon and Shoorji Vallabhdas, must be applied. Therefore, the enquiry for the Court is whether, as a result of the amalgamation, the assessee

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 INCOME TAX vs. M/S JINDAL STEEL THROUGH ITS MANAGING DIRECTOR

Appeals are hereby dismissed

C.A. No.-013771-013771 - 2015Supreme Court06 Dec 2023

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

Section 260ASection 80

9 Rs.48,11,72,000.00 as against Rs.80,10,38,505.00 claimed by the assessee. 9.1. In its order dated 07.06.2007, Tribunal noted that the dispute between the parties related to the manner of computing profits of the undertaking of the assessee engaged in the business of generation of power for the purpose of relief under Section

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

M/S. PUROLATOR INDIA LTD. vs. COMMNR. OF CENTRAL EXCISE, DELHI-III

Appeal is disposed of accordingly

C.A. No.-001959-001959 - 2006Supreme Court25 Aug 2015
Section 11ASection 11A(1)Section 38ASection 4

139 (T). The provision of Section 4 of the Central Excise Act have since then completely changed. As per new Section 4. Value shall "in a case where the goods are sold by the assessee, for delivery at the time and place of the removal, the assessee and the buyers of the goods are not related and the price

VODAFONE IDEA LTD(EARLIER KNOWN AS VODAFONE MOBILE SERVICES LIMITED vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 26 (2)

C.A. No.-002377-002377 - 2020Supreme Court29 Apr 2020

Bench: HON'BLE THE CHIEF JUSTICE

Section 143(2)Section 244ASection 92

Transfer Pricing Adjustment, Capitalization of Licence Fees, 3G Spectrum Fees, Asset Restoration Cost Obligation including the effect of amalgamation of group entities which required thorough scrutiny and determination. G] During the pendency of said Writ Petition, a letter was issued by the respondent No.1 on 23.07.2018, the relevant portion of which was as under :- "The assessment years for which request

SHREE CHOUDHARY TRANSPORT CO. vs. INCOME TAX OFFICER

C.A. No.-007865-007865 - 2009Supreme Court29 Jul 2020

Bench: HON'BLE MR. JUSTICE DINESH MAHESHWARI

Section 40

Price Waterhouse: (1997) 93 Taxman 588, the learned counsel has argued that when the words are clear and there is no obscurity, the intention of legislature has to be inferred only from the words used in the provision. 17 10.2.2. Thus, learned counsel for the appellant has strenuously argued that Section 40(a)(ia) of the Act remains limited

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

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

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

NEW DELHI TELEVISION LTD vs. DEPUTY COMMISSIONER OF INCOME TAX

C.A. No.-001008-001008 - 2020Supreme Court03 Apr 2020

Bench: HON'BLE MR. JUSTICE L. NAGESWARA RAO

Section 142(1)Section 143Section 143(2)Section 148

139   or   in   response   to   a   notice   issued   under   sub­ section (1) of section 142 or section 148 or to disclose fully and truly all material facts necessary for his assessment for that assessment year: Provided further that nothing contained in the first proviso shall apply in a case where any income in relation to any asset (including   financial   interest

COMMNR. OF CUSTOMS, MUMBAI vs. M/S. B.V. JEWELS AND ORS.'

The appeals are allowed to the extent indicated

C.A. No.-004254-004260 - 2003Supreme Court14 Sept 2004
For Respondent: M/s B.V. Jewels and Ors
Section 112Section 114Section 125(1)Section 125(2)Section 28Section 28(2)

9) Penalty of Rs.5 crores was imposed on M/s B.V. Jewels under Section 112(a) and 114(i) of the Act. (10) Penalty of Rs.10,00,000/- was imposed each on Mr. Suresh Mehta and Mr. Suken Mehta. (11) Penalty of Rs.2,00,000/- was imposed on Mrs. Saroj Mehta, Mrs. Sapna Mehta, Shivani Mehta, Mr. B.V. Shah, Mr. Rajesh

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