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7 results for “transfer pricing”+ Section 201(3)clear

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Key Topics

Section 17(5)(d)7Deduction3Section 1922Section 402Section 115Q2TDS2Addition to Income2

GENPACT INDIA PRIVATE LIMITED vs. DEPUTY COMMISSIONER OF INCOME TAX

C.A. No.-008945-008945 - 2019Supreme Court22 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

CHIEF COMMISSIONER OF CENTRAL GOODS AND SERVICE TAX vs. M/S SAFARI RETREATS PRIVATE LIMITED

Appeals are partly allowed in above terms

C.A. No.-002948-002948 - 2023Supreme Court03 Oct 2024

HON'BLE MR. JUSTICE ABHAY S. OKA

Bench:
Section 17Section 17(5)(c)Section 17(5)(d)

price of services they supply, i.e., renting/leasing/letting out, etc. Further, CGST is leviable on the supply of these services, resulting in tax on tax or the cascading effect of tax. Moreover, due to the denial of ITC, the assessees have to bear the tax burden. Thus, the interpretation put by revenue to clauses (c) and (d) of Section

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

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

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

THE BANK OF RAJASTHAN LTD. vs. COMMISSIONER OF INCOME TAX

Appeals are dismissed

C.A. No.-003291-003294 - 2009Supreme Court16 Oct 2024

Bench: HON'BLE MR. JUSTICE ABHAY S. OKA

Section 18Section 19Section 20Section 21

3)   the   ‘other   sources’   referred   to   in Section   12   of   the   Indian   Income   Tax Act.” The Appellate Assistant Commissioner, however, repelled the contention of the appellant. He held that the business of the appellant consisted of ‘lending   money,   and   selling   agricultural   and other products to its constituents’ which could be planned ahead and required no provision for extraordinary   claims

COMMR.OF INCOME TAX,BANGALORE vs. M/S INFOSYS TECHNOLOGIES LTD

C.A. No.-003725-003725 - 2007Supreme Court04 Jan 2008
For Respondent: Infosys Technologies Ltd
Section 17(2)(iii)Section 192

price paid by the employees for exercise of the option. He, therefore, treated Rs. 165 crores as \023perquisite value\024 on which TDS was charged at 30%. It was held that the respondent-assessee was a defaulter for not deducting TDS under Section 192 amounting to Rs. 49.52 crores on the above perquisite value of Rs. 165 crores. Similar orders