Search Results for "Arms Length Price"

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Search Results for "Arms Length Price"

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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 Upholds Validity of Explanations to Rule 38 of MCR, 2016 and Rule 45(8)(a) of MCDR, 2017 — Royalty Computation on Gross Sale Value Without Deduction of Royalty, DMF, and NMET Contributions is Valid. The Court held that royalty is a tax and not a contractual consideration, and the impugned explanations do not violate Article 14 or Article 265 of the Constitution.

15 Nov 2024

The petitioners, Kirloskar Ferrous Industries Limited and another, filed a writ petition under Article 32 of the Constitution challenging the validity...

High Court

Bombay High Court Dismisses Revenue's Appeal in Income Tax Reopening Case — Transfer Pricing Reference Invalid Without Pending Assessment Proceedings. The court upheld the ITAT's decision that the Assessing Officer lacked jurisdiction to issue notice under Section 148 of the Income Tax Act, 1961, as the reference to the Transfer Pricing Officer under Section 92CA was made without any pending assessment proceedings, rendering the TPO's order null and void ab initio.

7 Jun 2023

The case involves an appeal by the Pr. Commissioner of Income Tax – 6 against the order of the Income Tax Appellate Tribunal (ITAT) which had quashe...

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 Allows Petitions Challenging Denial of Denatured Spirit License for Industrial Use. Held that rectified spirit/denatured spirit is not 'intoxicating liquor' under the Bombay Prohibition Act, 1949 and that the State cannot refuse license for industrial use under the Bombay Denatured Spirit, Methyl Alcohol and Varnish (Miscellaneous) Rules, 1954.

27 Feb 2017

The petitioners, M/s. Biostar Pharmaceuticals Limited and Mr. Ashok Bora, filed two writ petitions challenging the refusal of the State Excise authori...

High Court

Bombay High Court Acquits Accused in Murder Case Due to Unreliable Sole Eyewitness Testimony and Lack of Corroboration. Conviction under Sections 302, 307 IPC and Section 30 Arms Act set aside as medical and ballistic evidence contradicted the eyewitness account.

25 Jul 2016

The case involves two criminal appeals arising from a judgment dated 29.12.2006 passed by the Additional Sessions Judge, Satara in Sessions Case No.53...

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 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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