Search Results for "Section 92C"

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Search Results for "Section 92C"

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High Court

High Court of Karnataka Dismisses Revenue's Appeal in Transfer Pricing Adjustment Case — No Substantial Question of Law Arises. The court upheld the ITAT's decision to delete the transfer pricing adjustment made by the Revenue, finding that the comparable selection and benchmarking analysis were correctly applied under Section 92C of the Income Tax Act, 1961.

12 Sep 2025

The Revenue filed appeals under Section 260A of the Income Tax Act, 1961, against a common order dated 08.11.2024 passed by the Income Tax Appellate T...

Supreme Court

Supreme Court Allows Revenue's Appeals in Transfer Pricing Cases, Remands to High Courts for Fresh Consideration. The Court Holds That High Court Can Examine Whether Tribunal Followed Guidelines Under Chapter X of Income Tax Act While Determining Arm's Length Price.

19 Apr 2023

The Supreme Court considered a batch of civil appeals, primarily by the Revenue, against judgments of various High Courts, particularly the Karnataka ...

Supreme Court

Supreme Court Allows Revenue's Appeal in Transfer Pricing Case — CBDT Instruction Not Mandatory. Assessing Officer's Power to Determine Arm's Length Price Under Section 92C(3) Upheld Despite Non-Reference to TPO.

13 Aug 2019

The case involves an appeal by the Principal Commissioner of Income Tax-4, Mumbai against the judgment of the Bombay High Court which dismissed the Re...

High Court

Bombay High Court Quashes TPO Order in Transfer Pricing Adjustment for Demerger Transaction. Held that transfer pricing provisions under Section 92 of Income Tax Act, 1961 do not apply to a demerger approved by High Court where assets and liabilities are transferred at book value without any consideration.

15 Mar 2019

The petitioner, Times Global Broadcasting Company Ltd, a wholly owned subsidiary of Benett, Coleman and Company Ltd (BCCL), was engaged in distributio...

High Court

Bombay High Court Upholds Reopening of Assessment Under Section 147(a) for Income Tax on Minimum Guarantee Receipts from Film Sale. Assessee's Failure to Disclose Full Consideration for Sale of Movie 'Charas' Justifies Reassessment Despite Partial Acceptance of Addition.

17 Nov 2017

The case involves an income tax reference at the instance of the assessee, who sold a movie titled 'Charas' to M/s. Prakash Pictures on a minimum guar...

High Court

Bombay High Court Dismisses Revenue Appeals in Transfer Pricing Adjustment Cases — Holds That Arm's Length Price Determination Must Be Based on Reliable Comparable Data and Functional Analysis. The Tribunal's deletion of adjustments was upheld as it correctly applied functional comparability and permissible adjustments under Section 92C of the Income Tax Act, 1961 and Rule 10B of the Income Tax Rules, 1962.

5 Dec 2014

The judgment involves a batch of appeals filed by the Revenue under Section 260A of the Income Tax Act, 1961, challenging the orders of the Income Tax...

High Court

Bombay High Court Dismisses Revenue's Challenge to Settlement Commission Order in International Taxation Case — Transfer Pricing Adjustments Not Required for Non-Resident Entities Without PE in India. Settlement Commission has exclusive jurisdiction to determine tax liability of non-resident entities, and transfer pricing provisions under Chapter X of Income Tax Act, 1961 do not apply to non-residents without permanent establishment in India.

28 Feb 2014

The case involves a writ petition filed by the Director of Income Tax (International Taxation), Mumbai, challenging an order dated 31 January 2008 pas...

High Court

Bombay High Court Quashes Reassessment Notice Under Section 148 of Income Tax Act for Lack of Fresh Material — Reassessment Based on Mere Change of Opinion Invalid. The court held that the Assessing Officer's acceptance of the return under Section 143(1) after considering the Section 10A deduction claim precludes reopening without fresh tangible material.

16 Sep 2013

The petitioner, Sitara Diamond Pvt. Ltd., challenged a notice dated 3 May 2012 issued under Section 148 of the Income Tax Act, 1961, seeking to reasse...

High Court

Bombay High Court Allows Revenue's Appeal in Transfer Pricing Case — Royalty on Bad Debts Not Deductible Without Actual Sales. ITAT erred in deleting disallowance of royalty paid on bad debts where software did not work, as no sale occurred.

3 Jul 2012

The case involves an appeal by the Commissioner of Income Tax under Section 260A of the Income Tax Act, 1961, against an order of the Income Tax Appel...

High Court

Bombay High Court Allows Writ Petition Challenging Transfer Pricing Reference and Order for Lack of Proper Approval Under Section 92D of Income-tax Act, 1961. The court held that the reference made by the Assessing Officer to the Transfer Pricing Officer without obtaining the requisite approval was invalid, and the subsequent order of the TPO was also invalid.

23 Dec 2011

The petitioner, M/s. Hindalco Industries Ltd., filed a writ petition under Article 226 of the Constitution challenging (i) an order dated 31 October 2...

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