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2 results for “transfer pricing”+ Section 92D(1)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

1) and sub-section (2) of section 120 of the Income-tax Act, 1961, the Central Board of Direct Taxes hereby directs that the Transfer Pricing Officers mentioned in column 2 having their headquarters mentioned in column 3 shall exercise such powers and perform such function of Transfer Pricing Officers as mentioned in Section 92CA for the purpose of sections

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

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. It is submitted that therefore