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2 results for “transfer pricing”+ Section 92A(2)clear

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THE PRINCIPAL COMMISSIONER OF INCOME TAX 4 MUMBAI vs. M/S S.G. ASIA HOLDINGS (INDIA) PVT. LTD

The Appeal is allowed to the aforesaid extent

C.A. No.-006144-006144 - 2019Supreme Court13 Aug 2019

Bench: HON'BLE THE CHIEF JUSTICE

Section 143(3)Section 92

92A Date of issue of notice to taxpayer Transfer price as taken by the taxpayer Arms length price as determined by the Transfer Pricing Officer under section 92CA (3) Method applied Reference to any database adopted by TPO `Date of despatch of the order of the A.O. ANNEXURE II Order under section 120, read with section 92CA of the Income

SAP LABS INDIA PRIVATE LIMITED vs. INCOME TAX OFFICER CIRCLE 6 (1) (1) BANGALORE

Appeals are allowed

C.A. No.-008463-008463 - 2022Supreme Court
19 Apr 2023

Bench: HON'BLE MR. JUSTICE M.R. SHAH

92A to 92CA, 92D, 92E and 92F and Rules 10A to 10E of the Income Tax Rules, 1962 (for short, ‘IT Rules’). It is submitted that under the scheme of transfer pricing, the arm’s length price is to be determined taking into consideration the guidelines stipulated under the aforesaid provisions of the IT Act and the Rules