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Search Results for "arm's length"

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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...

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 ...

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 Upholds Conviction of Three Accused in Murder Case Based on Ocular Evidence. Related Witnesses' Testimony Found Credible Despite Minor Discrepancies with Medical Evidence.

11 Dec 2019

The case arises from a murder that occurred on 17 June 1982. The deceased, Sarman Singh, had a prior altercation with accused Lakhan Singh over a land...

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 Rejection of Arm License for Social Worker and Businessman — District Magistrate's Order Set Aside for Non-Application of Mind and Failure to Consider Relevant Material. Licensing Authority Must Apply Mind to Police Report and Applicant's Grounds Before Rejecting Application Under Section 13 of Arms Act, 1959.

23 Jul 2019

The petitioner, Shafique Ahmed Mohammed Rafique, a businessman and social worker, filed a writ petition before the Bombay High Court challenging the o...

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 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...

High Court

Bombay High Court Partially Allows Appeal Against Conviction for Murder and Unlawful Assembly, Upholds Acquittal of Co-Accused. Conviction under Sections 302, 307, 148, 144, 143, 147 IPC and Arms Act based on eyewitness testimony and recovery of weapons, but acquittal of other accused under Section 302/34 IPC upheld due to lack of common intention.

19 Oct 2010

The judgment arises from two appeals: Criminal Appeal No. 864 of 2000 filed by accused Nos. 2 and 6 (Vijay Ramchandra Thopate and Ganpat Bhikaji Baman...

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