Novel Inc. vs DDIT
Royalty v. Business income-Sale of: software, Copyrighted products-Ay-2007-2008. The assessee was a company of USA. Under a joint venture with NIPL it received certain amount from NIPL for direct sale of software. Thi [LexDoc Id : 423180]
ITAT (Mumbai)
2011
CIT vs Amadeus India (P) Ltd.
Powers of T.P.O- Transactions not referred by A.O.-Law applicable-Ay- 2006-07. The TPO could not determine the ALP in respect of transcriptions not referred to by the A.O.
The powers as conferred by sub. S. (2 [LexDoc Id : 423038]
Merieux Alliance, In re
Rejection of: Application for Advance Ruling-Colorable device_ Business Scheme-The applicant is a French company. It along with another French company ‘G’ floated a 100% subsidiary and acquired majority shares of an Indian compan [LexDoc Id : 422314]
Nokia India (P) Ltd. vs Addl. CIT
Business expenditure-Obsolescence allowance-The assessee filed item-wise details of obsolescence, the basis for provision made and copy of global policy in this regard. The ad hoc disallowance a [LexDoc Id : 427267]
Ranbaxy Laboratories Ltd. vs CIT
Erroneous Order-Not following CBDT's instructions-A.Y. 2004-2005. The A.O. failed to make a reference to TPO as per CBDT's instructions. It was an erroneous order.
S.263 and s.92CA (4) of the Inc [LexDoc Id : 423297]
HC (Delhi)
2011
ACIT vs Meru Impex
Income deemed to accrue in India-Independent personal services-On above stated facts, since no services were rendered by ‘SB’ made under s.195 and so no disallowance under s.40(a)(iii)
Ss.40(a)(iii) and 195 of th [LexDoc Id : 423181]
ITAT (Mumbai)
2011
WSA Shipping Bombay (P) Ltd. vs ADIT
P.E.vis-a-vis Agent of Non-resident-Business associate v. Agent, Business of: cargo consolidation-Ay-2002-2003, 2003-2004. A company ‘W.L.’ was in business of cargo consolidation. It received cargo from shippers at various ports and container freig [LexDoc Id : 421619]
SEPCO III Electric Power Construction Corpn., In re
Rectification of mistake-Mistake v. Review of orders-The applicant filed the return of income and later filed application for Advance Ruling under s.245Q. The application was rejected by AAR on the groun [LexDoc Id : 422315]
Ardex Investments Mauritius Ltd., In re
Income deemed to accrue in India-Sale of shares by N.R. to N.R.-The non-resident company proposes to sell shares of an Indian company to another non-resident at fair market price.
DTAA applicable.
The ori [LexDoc Id : 421291]
Global Offshore International Ltd. vs Addl. CIT
Duty of: Dispute Resolution panel -Passing a : speaking order-The dispute was on applicability of S.44BB. The DRP did not consider activities of assessee nor examined assessee’s objections and passed a non-speaki [LexDoc Id : 423211]
Trigent Software Ltd. vs ACIT
Computation of ALP-FAR analysis must-A.Y. 2006-07. The assessee and TPO both did transfer pricing analysis but neither did FAR analysis i.e.:-
- Functions performed
- [LexDoc Id : 426818]
