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Search Results for "income tax transfer"

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Supreme Court

Supreme Court Upholds Revenue's Assessment Under Section 44D of Income-tax Act Despite Income Not Being Taxable at Time of Asset Transfer. Partners of Firm That Transferred Assets to Non-Resident Corporation Assessable on Corporation's Income as They Acquired Right to Enjoy Income by Means of Transfer.

29 Nov 1965

The case arose from a dispute under the Indian Income-tax Act, 1922 concerning the assessment of partners of a firm that had transferred assets to a n...

High Court

Bombay High Court Quashes Reassessment Order in Capital Gains Tax Case — Transfer of Shares of Foreign Company Not Taxable in India. Shares of a Bermuda company transferred outside India do not constitute transfer of a capital asset situated in India under Section 2(14) of the Income Tax Act, 1961.

18 Mar 2016

The petitioner, Techpac Holdings Ltd., a company incorporated in Bermuda, challenged an assessment order dated 25th March 2013 passed by the Deputy Co...

High Court

High Court of Karnataka Dismisses Assessee's Appeal in Transfer Pricing Case — No Substantial Question of Law Found. The ITAT's findings on arm's length price for software development services were based on evidence and not perverse, hence no interference under Section 260-A of the Income Tax Act, 1961.

26 Jun 2018

The assessee, M/s. Indigra Exports Pvt. Ltd., filed an appeal under Section 260-A of the Income Tax Act, 1961 against the order of the Income Tax Appe...

High Court

Bombay High Court Quashes Transfer of Income Tax Case from Pune to Mumbai for Lack of Proper Hearing and Application of Mind. Transfer under Section 127(2) of Income Tax Act, 1961 set aside as Commissioner failed to consider petitioner's objections and did not provide reasons for transfer.

5 Mar 2013

The petitioner, Shikshana Prasaraka Mandali, a public charitable trust established in 1888 engaged in running educational institutions, challenged the...

High Court

Bombay High Court Quashes Transfer of NRI Assessee's Case Under Section 127 of Income Tax Act, 1961 Due to Violation of Natural Justice. Show-Cause Notice Not Served and Reply Not Considered Before Centralization of Case from Mumbai to Delhi.

26 Aug 2024

The petitioner, Rajiv Saxena, a Non-Resident Indian living in Dubai since 1992, filed a writ petition under Article 226 of the Constitution of India c...

High Court

Bombay High Court Hears Writ Petition Challenging Taxation of Alleged Shortfall in Share Premium Under Transfer Pricing Provisions. The Dispute Centers on Whether Chapter X of the Income Tax Act, 1961 Can Apply When No Actual Income Arises from the International Transaction.

10 Oct 2014

The petitioner, Vodafone India Services Pvt. Ltd., a wholly owned subsidiary of a non-resident holding company, issued 2,89,224 equity shares at a pre...

High Court

High Court of Karnataka Dismisses Revenue's Appeal in Transfer Pricing Adjustment Case — Held that ITAT Correctly Deleted Addition for Non-Compete Fee Paid to AE Without Adequate Justification. The court found no substantial question of law as the Tribunal's findings were factual and not perverse.

14 Aug 2015

The Revenue (Commissioner of Income Tax and Assistant Commissioner of Income Tax) filed appeals under Section 260A of the Income Tax Act, 1961 against...

High Court

Bombay High Court Dismisses Revenue's Challenge to AAR Order on Capital Gains Tax Exemption for Non-Resident Share Transfer. Transfer of shares by non-resident to another non-resident outside India does not attract capital gains tax under Section 9(1)(i) of Income Tax Act, 1961 as the shares are not situated in India.

25 Nov 2016

The Commissioner of Income Tax, Goa, filed a writ petition challenging two orders dated 12.03.2010 and 15.06.2010 passed by the Additional Commissione...

Supreme Court

Supreme Court Hears Appeal on Taxability of Capital Gains from Transfer of Shares of a Cayman Islands Company Holding Indian Telecom Assets. The core issue involves whether the offshore transaction is liable to capital gains tax in India under the Income Tax Act, 1961, given that the company's value is derived from Indian telecom assets.

1 Aug 2026

The matter concerned a tax dispute between Vodafone International Holdings BV (VIH), a Netherlands resident company, and the Indian Revenue authoritie...

High Court

High Court of Karnataka Hears Revenue's Appeal Against Income Tax Appellate Tribunal Order Deleting Transfer Pricing and Bogus Expense Additions for Assessment Year 2009-10. The Appeal Involves Interpretation of Associated Enterprise Under Section 92A and Right of Cross-Examination When Additions Are Based on Third-Party Statements.

17 Mar 2023

The Revenue filed an appeal under Section 260A of the Income Tax Act, 1961 before the High Court of Karnataka, Dharwad Bench, challenging the order da...

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