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

The appeals are allowed

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

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 are principally related to the transfer pricing functions and international taxation which are presently

COMMISSIONER OF INCOME TAX vs. UNITED PROVINCES ELECTRIC SUPPLY CO

In the result, appeal is allowed

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

Bench: HON'BLE MR. JUSTICE R. MAHADEVAN

2 WLR 449 : (1981) 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

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

2) it was stated that the purchaser would purchase the property from the seller at the stated price. Upon construing the terms 26 Page 27 JUDGMENT of the conditions, it was opined: (SCC p. 749, para 24) “24. Therefore, the process licence fees of DM 20,00,000 was rightly added to the purchase price by the Collector of Customs

RAMNATH AND CO. vs. THE COMMISSIONER OF INCOME TAX

Bench: HON'BLE MR. JUSTICE DINESH MAHESHWARI

2 (4) of the agency agreement regarding marine products entered into between Gelazur S.A. and Ramnath & Co. (assessee) states that the assessee is to inform “GELAZUR” regularly about the market situation, i.e. fishing situation, prices paid by other markets, prices paid by French Competitors, business opportunities, monthly supplies of seafood data. This indicates that the assessee has to communicate

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

The appeal is allowed accordingly

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

2 of 5 In an appeal preferred by the company the Commissioner of Income-tax held that the said amount could not be brought to tax. The Revenue preferred an appeal before the Appellate Tribunal which was dismissed. However, the abovesaid question of law was referred by the Tribunal for the opinion of the High Court at the instance

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

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