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7 results for “transfer pricing”+ Section 271(1)(b)clear

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Key Topics

Section 806Section 403Section 143(3)2Section 115Q2Deduction2

DILIP N. SHROFF vs. JOINT COMMNR. OF INCOME TAX, MUMBAI &ANR

The appeal is allowed

C.A. No.-002746-002746 - 2007Supreme Court18 May 2007
For Respondent: Joint Commissioner of Income Tax, Mumbai & Anr

b) and (c) of Section 271(1) have been satisfied would be reached only after the assessee has been heard or has been given a reasonable opportunity of being heard." 61. It may be true that the legislature has attempted to shift the burden from revenue to the assessee. It may further be correct that different views have been expressed

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

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

1. GRANT OF LICENSE: This EULA grants you the following rights: a. Systems Software - You may install and use one copy of the SOFTWARE PRODUCT on a single computer, including a workstation, terminal, or other digital electronic device (“COMPUTER”). You may permit a maximum of five (5) COMPUTERS to connect to the single COMPUTER running the SOFTWARE PRODUCT solely

KERALA STATE BEVERAGES MANUFACTURING AND MARKETING CORPORATION LIMITED vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 1(1)

Accordingly, the civil appeal filed by the assessee is dismissed

C.A. No.-000011-000011 - 2022Supreme Court03 Jan 2022

Bench: HON'BLE MR. JUSTICE R. SUBHASH REDDY

Section 143(3)Section 263Section 40

transfer, went into the Consolidated Fund of the States and on this basis constitutional protection under Article 289 were claimed as a result of which, these amounts could neither be taxed in the hands of the State Government Undertakings nor in the hands of the respective States.  Precisely the underlined   spirit   in   bringing   out   the   said   amendment   by   inserting Section

K. KRISHNAMURTHY vs. THE DEPUTY COMMISSIONER OF INCOME TAX

Appeal is disposed of with

C.A. No.-002411-002411 - 2025Supreme Court13 Feb 2025

Bench: HON'BLE MR. JUSTICE DIPANKAR DATTA

Section 132Section 139(1)Section 142(1)Section 260A

price from the land procurers, i.e. the Appellant and Mr. Surendra Reddy. As per Clause 10 of this MOU, Rs.10,00,000/- (Rupees Ten lakhs only) was paid to the procurers for arranging facilitation of transfer of land from the landowners to Mr. Hashim Moosa/his nominees. No other payment, except a reimbursement under Clause 11, was contemplated under this

COMMNR. OF CUSTOMS (GENERAL), N. DELHI vs. GUJARAT PERSTORP ELECTRONICS LTD

The appeals are allowed

C.A. No.-008568-008569 - 2001Supreme Court05 Aug 2005
For Respondent: M/s. Gujarat Perstorp Electronics Ltd
Section 28(1)

271, were correct. CEGAT proceeded to state that after a survey on the entire case law, the Larger Bench in Parasrampuria Synthetics Ltd. took the view that the law laid down by two-member Bench in Tractors & Farm Equipment Ltd. did not lay down correct law and accordingly overruled it. The decisions in other cases were correct and the said

RAMNATH AND CO. vs. THE COMMISSIONER OF INCOME TAX

C.A. No.-002506-002509 - 2020Supreme Court05 Jun 2020

Bench: HON'BLE MR. JUSTICE DINESH MAHESHWARI

Section 80

transferring information abroad would not establish that the service is rendered from India and not in India; that all receipts cannot qualify for concession; that the range of services referred to in Section 80-O of the Act have the thread of connectivity in all the intellectual endeavours mentioned therein. The High Court summed up its discussion in the following