Paton vs ITO
Allotment of Conversion deed-Additional Evidence: Contravention to Rule 46A of the Income Tax Rules 1962 -Whether, CIT(A) had admitted additional evidence in allowing relief to the assessee in contravention of Rule 46A of the Income Tax Rules, 1962. Held, [LexDoc Id : 475421]
ITAT (Mumbai)
2014
Morgan Stanley International Incorporated vs DDIT
Deputation of Seconded Employees-Section 195 of the Income tax Act 1961. Tax Deduction At Source for Seconded Employees: India-US Double Tax Avoidance Agreement-Assessee-Company was a resident of USA and it was a 100% subsidiary of M/s Morgan Stanley USA. Assessee had deputed five of its employees in terms of [LexDoc Id : 475420]
ACIT vs Mosaic India (P) Ltd.
Arm’s length Pricing for Quality of goods-Adjustment Benefit on + 5% under Section 92C(2) of the Income Tax Act 1961-Whether, TPO rightly ignored the + 5% adjustment benefit under the proviso to section 92C(2) made available to the assessee. Held, Revenue rightly obs [LexDoc Id : 475406]