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4 results for “transfer pricing”+ Section 92Cclear

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Key Topics

Section 144C6Section 1532Section 153(1)2Section 652Addition to Income2

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

price has already been given by the TPO and, therefore, opportunity by the Assessing Officer, for final determination of income under sub-section (4) of section 92C, read with sub-section (4) of section 92CA is to be given by the Assessing Officer. (iv) Maintenance of database: It is to be ensured by the DIT (Transfer

ASSISTANT COMMISSIONER OF INCOME TAX vs. SHELF DRILLING RON TAPPMEYER LIMITED

The appeals are allowed

C.A. No.-010586-010589 - 2025Supreme Court08 Aug 2025

HON'BLE MRS. JUSTICE B.V. NAGARATHNA

Bench:
Section 144CSection 153Section 153(1)Section 44B

Transfer Pricing Officer, then under Section 92CA of the Act as there is an extension of the period of twenty-one months contemplated under Section 153(1) of the Act by a further period of twelve months, the total time period is increased to thirty-three months for passing an assessment order from the end of the relevant year. That

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

Appeals are allowed

C.A. No.-008463-008463 - 2022Supreme Court19 Apr 2023

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

Transfer Pricing provisions are essentially a valuation exercise involving determination of a statistical sample of comparables. Under Section 92C(2) of the IT Act, Arm’s Length

COMMISSIONER OF GST AND CENTRAL EXCISE vs. M/S CITIBANK N.A

C.A. No.-008228 - 2019Supreme Court09 Dec 2021

Bench: HON'BLE MR. JUSTICE K.M. JOSEPH

Section 35L(1)(b)Section 64(3)Section 65Section 65(10)Section 65(105)Section 65(12)Section 65(7)Section 83

Section 66 B accompanied by the definition of service under Section 65B (44) and the legislature further providing for the negative 80 list of services which stood excluded from the levy of service tax in Section 66 D, the question would only be whether there is any service and whether it is excluded under Section 66 D. The relevant part