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2 results for “transfer pricing”+ Section 153Aclear

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Key Topics

Section 144C6Section 1532Section 153(1)2Section 115Q2

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

153A or sub-section (5) of section 158BA, shall be made within a period of one year from the end of the month of such revival or within the period specified in this section or sub-section (1) of section 153B or section 158BE, whichever is later. (9) The provisions of this section as they stood immediately before the commencement

GENPACT INDIA PRIVATE LIMITED vs. DEPUTY COMMISSIONER OF INCOME TAX

C.A. No.-008945-008945 - 2019
Supreme Court
22 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