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Search Results for "Transfer pricing"

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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

Bombay High Court Allows Writ Petition for Non-Compliance of DRP Directions Within Statutory Time Limit Under Section 144C(13) of Income Tax Act, 1961. Failure to Complete Assessment Within One Month of Receiving DRP Directions Renders Transfer Pricing Addition Time-Barred and Non-Est.

10 Oct 2025

The Petitioner, Archroma International (India) Private Limited (formerly Huntsman International (India) Private Limited), filed a Writ Petition under ...

High Court

Bombay High Court Allows Public Interest Litigation Seeking Preservation of Land for Government Sports Complex at Navi Mumbai — Directs Restoration of Earmarked Land and Cancellation of Allotment to Private Developer. Land reserved since 2003 under Government Resolution dated 26 March 2003 for a Government Sports Complex cannot be diverted for commercial purposes; shifting the complex to a remote rural area 115 km away is arbitrary.

1 Jul 2024

The Indian Institute of Architects, Navi Mumbai Center, filed a Public Interest Litigation before the Bombay High Court challenging the actions of CID...

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...

High Court

Bombay High Court Allows Revenue's Appeal in Transfer Pricing Case Due to Non-Application of Mind by ITAT. Tribunal's order set aside for failing to consider the TPO's detailed analysis and rejecting comparables without proper reasoning under Section 92C of the Income Tax Act, 1961.

27 Feb 2020

The appeal was filed by the Pr. Commissioner of Income Tax - 6 under Section 260A of the Income Tax Act, 1961 against the order of the Income Tax Appe...

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 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.

13 Oct 2014

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...

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...

Supreme Court

Supreme Court Dismisses Revenue Appeal in Income Tax Limitation Case Under Section 144C. Nagarathna J. Holds That Section 144C Does Not Extend Limitation Under Section 153 of Income Tax Act, 1961.

1 Jan 1970

This separate opinion by Nagarathna J. arises from civil appeals filed by the Revenue against a common order of the Bombay High Court. The High Court ...

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