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3 results for “transfer pricing”+ Section 246Aclear

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Key Topics

Section 17(5)(d)7Section 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

246A deals with appeals before the Commissioner (Appeals) which is essentially with regard to an assessment order passed under sub-section (3) of Section 143 or sub-section (12) of Section 144BA or Section 144 made by the Assessing Officer. However, any order passed in pursuance of the directions of the DRP is not appealable to the Commissioner (Appeals

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

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

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

Section 17Section 17(5)(c)Section 17(5)(d)

price, upon which further GST would be levied, leading to tax Civil Appeal No.2948 of 2023 etc. Page 9 of 91 on tax. If what is being supplied by the seller is a service, it has to be necessarily received as a service by the buyer; e. Section 17(5)(c) and (d) remain vague due to the absence