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10 results for “transfer pricing”+ Section 254(1)clear

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Key Topics

Section 144C6Section 104Section 65(105)(zzzzj)3Section 473Exemption3Section 1532Section 153(1)2Section 1082Section 452Addition to Income

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

1), (1A), (2), (3) and (3A), shall be extended by twelve months. (5) Where effect to an order under section 250 or section 254 or section 260 or section 262 or section 263 or section 264 is to be given by the Assessing Officer or the Transfer Pricing

COMMR.OF CUSTOMS (IMPORT) MUMBAI vs. M/S GANPATI OVERSEAS THR. ITS PROPRIETOR SHRI YASHPAL SHARMA

C.A. No.-004735-004736 - 2009Supreme Court
2
Capital Gains2
06 Oct 2023

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

Section 108Section 130

transfer of the differential amount. Therefore, the adjudicating authority opined that he had no reason to accept the plea of the respondents that the statements of Mr. Yashpal Sharma and Mr. Suresh Chandra Sharma were not voluntary and should not be relied upon. This plea was taken only as an afterthought. 14 6.3. Contention of the respondents that the declared

RAJ PAL SINGH vs. COMMISSIONER OF INCOME TAX HARYANA

In the result, this appeal fails and is, therefore, dismissed

C.A. No.-002416-002416 - 2010Supreme Court25 Aug 2020

Bench: HON'BLE MR. JUSTICE DINESH MAHESHWARI

Section 256(1)Section 4Section 45Section 6

price of the land fixed by the Collector to the land owners. From the copy of the jamabandi attached with this file, khasra Nos. 361 and 364 measuring 5 kanals and 7 marlas were not on the lease with the college. But the Management is claiming compensation for this land also. In these circumstances, the college management cannot be awarded

M/S JINDAL EQUIPMENT LEASING CONSULTANCY SERVICES LTD. vs. COMMISSIONER OF INCOME TAX

Appeals stand disposed of in the aforesaid terms

C.A. No.-000152-000152 - 2026Supreme Court09 Jan 2026

Bench: HON'BLE MR. JUSTICE R. MAHADEVAN

Section 143(3)Section 28Section 47

254 (SC) 31 15.3. It therefore emerges that Section 28 is a comprehensive charging provision designed to bring within the tax net all real profits and gains arising in the course of business, whether convertible into money or received in money or in kind, and irrespective of whether such accrual or receipt of income is accompanied by a legal transfer

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

M/S QUEEN'S EDUCATIONAL SOCIETY vs. COMMR.OF INCOME TAX

C.A. No.-005167-005167 - 2008Supreme Court16 Mar 2015

Bench: The Uttarakhand High Court, Nainital, May Be Gleaned From The Facts Of One Of Them, Namely, The Queen’S Educational Society Case. The Appellant Filed Its Return For Assessment Years 2000-2001 & 2001-2002 Showing A Net Surplus Of Rs.6,58,862/- & Rs.7,82,632/- Respectively. Since The Appellant Was Established With The Sole 2

Section 10Section 10(22)Section 260A

254 : 1976 SCC (Tax) 14 : (1975) 101 ITR 234] : “[I]f the activity of a trust consists of carrying on a business and there are no restrictions on its making profit, the court would be well justified in assuming in the absence of some indication to the contrary that the object of the trust involves the carrying

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

price of shares. Therefore, in the mechanism of capital gains computation, what is relevant is not only the sale of shares but also the purchase of shares. Thus, the entire transaction of acquisition as well as sale 14 of shares, as a whole, is required to be examined, and a dissecting approach by examining only the sale of shares

SHIV RAJ GUPTA vs. COMMISSIONER OF INCOME-TAX, DELHI IV

C.A. No.-012044-012044 - 2016Supreme Court22 Jul 2020

Bench: HON'BLE MR. JUSTICE ROHINTON FALI NARIMAN

transfer of shares. This finding would clearly be in the teeth of Section 260-A (4), requiring the judgment to be set aside on this score. 15. Coming to the merits, the High Court found: “22. …No doubt, market price of each share was only Rs.3/- per share and the purchase price under the MOU was Rs.30/-, but the total

COMMISSIONER OF SERVICE TAX vs. M/S ADANI GAS LTD

The appeal is allowed in the above terms

C.A. No.-002633 - 2020Supreme Court28 Aug 2020

Bench: HON'BLE THE CHIEF JUSTICE

Section 65(105)(zzz)Section 65(105)(zzzzj)

1). 13 c. the transferee should have a legal right to use the goods- consequently all legal consequences of such use including any permissions or licenses required therefore should be available to the transferee; d. for the period during which the transferee has such legal right, it has to be the exclusion to the transferor; this is the necessary concomitant

M/S MARUTI SUZUKI LTD. vs. COMMR.OF CENTRAL EXCISE-III,DELHI

C.A. No.-005554-005554 - 2009Supreme Court17 Aug 2009

254 (E), dated the 16th March, 1995; (3) No. 63/95-Central Excise, dated the 16th March, 1995, G.S.R. 255 (E), dated the 16th March, 1995; (4) No. 64/95-Central Excise, dated the 16th March, 1995, G.S.R. 256 (E), dated the 16th March, 1995, the manufacturer shall pay an amount equivalent to the CENVAT credit attributable to inputs and input services used