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3 results for “transfer pricing”+ Section 246A(1)(b)clear

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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

b) of Section 144C(15). That insofar as an ordinary assessment is concerned, the time frame is as provided under Section 153 of the Act but if there is a variation arising in respect of a proceeding before the Transfer Pricing Officer, then under Section 92CA of the Act as there is an extension of the period of twenty

GENPACT INDIA PRIVATE LIMITED vs. DEPUTY COMMISSIONER OF INCOME TAX

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

Bench: HON'BLE THE CHIEF JUSTICE

Section 115QSection 143(2)Section 77A

b) On 10.05.2013, Chapter XIIDA consisting of Sections 115QA, 115QB and 115QC was inserted in the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) by the Finance Act, 2013 which came into effect from 01.06.2013. Section 115QA as it stood prior to the amendment which came into effect on 01.06.2016 was to the following effect: “Section 115QA

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)

b. There is no intelligible differentia on the basis of which such classification is done. Creation of an immovable property is not a differentia. The contention is that works contracts, namely the contracts for the construction of immovable property wherein transfer of property is involved, are treated as a supply of services. Therefore, de jure, they are treated