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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.

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

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Bombay High Court Dismisses Revenue's Appeal in Transfer Pricing Case — Advertisement Expenses Not Subject to Disallowance. Assessee's expenditure on promoting foreign channels held to be for its own business benefit, not requiring compensation from foreign principals.

The appeal was filed by the Commissioner of Income Tax against the order of the Income Tax Appellate Tribunal (ITAT) dated 29th July 2011, which confi...

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Bombay High Court Quashes Reassessment Notice Under Section 148 of Income Tax Act, 1961 for Non-Compliance with Procedural Requirements. Notice Issued Beyond Four-Year Limit Without Proper Sanction and Without Disclosing Reasons for Alleged Income Escaping Assessment.

The petitioner, Chennai Container Terminal Pvt. Ltd., challenged a notice dated 26 March 2021 issued under Section 148 of the Income Tax Act, 1961 by ...