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10 results for “transfer pricing”+ Section 195(1)clear

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Key Topics

Section 41(2)10Section 144C6Section 806Section 1532Section 153(1)2Section 256(1)2Section 11A(1)2Section 11A2Exemption2Limitation/Time-bar

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

1. GRANT OF LICENSE: This EULA grants you the following rights: a. Systems Software - You may install and use one copy of the SOFTWARE PRODUCT on a single computer, including a workstation, terminal, or other digital electronic device (“COMPUTER”). You may permit a maximum of five (5) COMPUTERS to connect to the single COMPUTER running the SOFTWARE PRODUCT solely

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)
2
Addition to Income2
Section 44B

1. 92CA Faceless determination of arm’s length price 31st day of March, 2022 2. 144C Faceless Dispute 31st day of March, 2022 Page 52 of 112 Resolution Panel 3. 253 Faceless appeal to Appellate Tribunal 31st day of March, 2022 4. 255 Faceless procedure of Appellate Tribunal 31st day of March, 2023 3. Section 92CA and section 144C

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

COMMISSIONER OF INCOME TAX vs. UNITED PROVINCES ELECTRIC SUPPLY CO

In the result, appeal is allowed

C.A. No.-006325-006325 - 1995Supreme Court17 Apr 2000
For Respondent: UNITED PROVINCES ELECTRIC SUPPLY COMPANY
Section 256(1)Section 32(1)Section 41(2)Section 6Section 7A

transfer, in a scheme of amalgamation, of any asset by the amalgamating company to the amalgamated company where the amalgamated company is an Indian company; Section 41 is under the heading Computation of Business Income. The entire section makes it abundantly clear that income arising as provided therein is to be considered as income of business or profession

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

1 All ER 865 (HL)] enunciated the look at test. According to that test, the task of the Revenue is to ascertain the legal nature of the transaction and, while doing so, it has to look at the entire transaction holistically and not to adopt a dissecting approach. 97. One more aspect needs to be reiterated. There is a conceptual

COMMNR. OF CUSTOMS, AHMEDABAD vs. M/S. ESSAR STEEL LTD

C.A. No.-003042-003042 - 2004Supreme Court13 Apr 2015

Sections 14 and 14(1-A) are clear and explicit. The Rules and the Act, therefore, must be construed, having regard to the basic principles of interpretation in mind. 11. What would, therefore, be excluded for computing the assessable value for the purpose of levy of customs duty, inter alia, has clearly been stated therein, namely, any amount paid

M/S DHARAMPAL SATYAPAL vs. COMNR. OF CENTRAL EXCISE, NEW DELHI

C.A. No.-001506-001508 - 2000Supreme Court21 Apr 2005
For Respondent: Commissioner of Central Excise, Delhi-I, New Delhi
Section 11ASection 11A(1)Section 35

transferred the compound (kimam). The said enquiries indicated receipt of the said compound (kimam) in balties at Barotiwala during the period 16.2.1995 to 20.12.1996. Based on the above investigations carried out by the department, it appeared that the compound (kimam) was excisable and had been manufactured and cleared without http://JUDIS.NIC.IN SUPREME COURT OF INDIA Page 2 of 8 obtaining

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

THE K.C.P. LTD vs. COMMR. OF INCOME TAX, BANGALORE

C.A. No.-007652-007652 - 1996Supreme Court09 Aug 2000
For Respondent: COMMISSIONER OF INCOME TAX, BANGALORE
Section 256(1)Section 3

1) of the Income-tax Act, 1961 has been answered in the negative, i.e., in favour of the Revenue and against the assessee:- Whether on the facts and in the circumstances of the case, the Appellate Tribunal is right in law in upholding the order of the Commissioner of Income Tax deleting Rs.14,96,130/- being the excess realisation over

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

1% OF THE C+F value Squids, cuttlefish, Cockies Mussels and other Fishes: USD O.65/Kg When the quality and the packaging of the goods are found to be unsatisfactory to ‘GELAZUR” after inspection in FRANCE, GELAZURE, shall have no responsibility regarding the payment of the Agent’s fee. Article 4: If any claim arises out of or in relation