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3 results for “transfer pricing”+ Section 144C(8)clear

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Key Topics

Section 144C6Section 143(2)4Section 1532Section 153(1)2Section 922Transfer Pricing2

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

8 of 112 operation of the TOLA and the Notifications issued thereunder, the due date was extended to 30.09.2021. Vide the Common Impugned Order, the High Court was of the view that there is no difference in the legal principle falling for consideration in all these petitions since, in these two petitions, the draft order under Section 144C was passed

PR. COMMISSIONER OF INCOME TAX vs. MARUTI SUZUKI INDIA LIMITED

C.A. No.-005409-005409 - 2019Supreme Court
25 Jul 2019

Bench: HON'BLE THE CHIEF JUSTICE

Section 142(1)Section 143(2)Section 260ASection 92C

Transfer Pricing Officer8 passed an order under Section 92CA (3) determining the Arm’s Length Price of royalty at 3 per cent and making an adjustment of Rs. 78.97 crores in respect of royalty paid by the assessee for the relevant previous year. 10 On 11 March 2016, a draft assessment order was passed in the name of Suzuki Powertrain

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