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Documents Found: 279 |
Title |
Forum |
Year |
DCIT vs Marconi Telecommunication India (P) Ltd.
ALP - ALP determined by TPO-Deletion of adjustments - Opportunity to TPO-A.Y. 2004-05.
The CIT(A) could not delete the adjustment made by TPO without giving him an opportunity being heard.
S. 92CA of the Income Ta [LexDoc Id : 443152]
|
ITAT (Delhi) |
2012 |
KHS Machinery (P) Ltd. vs ITO
[LexDoc Id : 429290]
|
ITAT (Ahmedabad) |
2012 |
Organisation Development Pte. Ltd. vs DDIT
F.T.S.-Management tools-Customized management tools Balance Score Card System-A.Y. 2007-08. The assessee a Co. of Singapore provided it's clients customized management tool i.e. Balance Score Card System. This required considera [LexDoc Id : 425993]
|
ITAT (Chennai) |
2012 |
Bechtel International Inc. vs ADIT
[LexDoc Id : 436857]
|
ITAT (Mumbai) |
2012 |
Bayer Bio Science (P) Ltd. vs ACIT
[LexDoc Id : 432289]
|
ITAT (Mumbai) |
2012 |
DDIT vs Solid Works Corpn.
Non-discrimination-Two views possible-The Revenue's plea was that where two views were possible, one in favor of assessee should be followed is also applicable to non-residents in view of [LexDoc Id : 423939]
|
ITAT (Mumbai) |
2012 |
Areva T and D India Ltd., In re
Fees for Technical Services- FTS.-"Making available" know-how/experience etc.-The consideration to be received for such services would be FTS being fees for making available know-how/ experience to be used for running the busine [LexDoc Id : 427505]
|
AAR |
2012 |
CIT vs I. Tech Electronics
"Manufacture"-Assembly of T.V. Sets-A.Y. 2004-05. The assessee assembled T.V. Sets from separate items like cabinets, circuits, picture tubes etc. purchased from market. It was manufactu [LexDoc Id : 425605]
|
HC (Gauhati) |
2012 |
Citrix Systems Asia Pacific Pty. Ltd., In re
Income deemed to accrue in India-Royalty-Licensing and sale of: software products - Sale thru: Distributors-The applicant an Australian Co. received payment from distributor for sale/licensing of software product in India. The payments received from distribu [LexDoc Id : 425341]
|
AAR |
2012 |
NetApp B.V., In re
Application for: Advance Ruling-Pendency of return vis-ŕ-vis pendency of proceedings-The date of filing of the return would decide whether the issue was pending before the income-tax authority. The initiation or otherwise of the procee [LexDoc Id : 426570]
|
AAR |
2012 |
CTCI Overseas Corpn. Ltd., In re
"Business Connection" : Offshore supply of equipment-Consortium with India Co.-The applicant a Hong Kong Co. formed a consortium with an Indian Co. CINDA for development of a terminal for natural gas. It was responsible for off-s [LexDoc Id : 425342]
|
AAR |
2012 |
Directorate of Enforcement vs Subhash Muljimal Gandhi
Seizure of currency: Seizure by police-Empowerment of other officers including police to affect seizure, Fact of initial seizure by police or by DOE irrelevant, Seizure deemed to be under s.37 of FEMA 1999-Rule 8of the Foreign Exchange Management (Encashment of Draft, Cheque, Instrument and Payment of Interest) Rules 2000 was expressly made applicable to [LexDoc Id : 422877]
|
HC (Delhi) |
2012 |
Cheil India (P) Ltd. vs ACIT
[LexDoc Id : 427933]
|
ITAT (Delhi) |
2012 |
Lason India (P) Ltd. vs ACIT
Computation of: ALP/operative profits-Marginal difference in rate of depreciation-A.Y. 2007-08. There was only a marginal difference in rate of depreciation adopted by assessee and that taken by TPO. The writing back of excess depre [LexDoc Id : 426225]
|
ITAT (Chennai) |
2012 |
Kodiak Networks India (P) Ltd. vs ACIT
Computation of deduction-Computation of export turnover and total turnover-The expenses excluded from export turnover should be excluded from total turnover.
S. 10A of the Income Tax Act, 1961. [LexDoc Id : 427502]
|
ITAT (Bangalore) |
2012 |
Lionbridge Technologies (P) Ltd. vs DCIT
[LexDoc Id : 427152]
|
ITAT (Mumbai) |
2012 |
Glaxo Smithkline Consumer Healthcare Ltd. vs Addl. CIT
Powers of TPO-ALP of transaction not referred by A.O.-A.Y. 2006-07. The TPO suo moto could not decide the ALP of a transaction not referred to by A.O.
S. 92CA of the Income Tax Act, 1961.
[Ed [LexDoc Id : 426773]
|
ITAT (Chandigarh) |
2012 |
CGG Veritas Services, SA vs Addl. DIT
Income from: Exploration etc-of mineral oil-Geophysical and geological services-The assessee was French Co. It derived income from execution of exploration projects for prospecting deposits of mineral oil in offshore waters. It co [LexDoc Id : 425985]
|
ITAT (Delhi) |
2012 |
Knoah Solutions (P) Ltd. vs ITO
Computation of: ALP-BPO services-Comparable cases vis-ŕ-vis loss making companies-Additional comparable case-A.Y. 2004-05.
The assessee was a 100% subsidiary of a foreign company. It rendered BPO services to it's AEs.
During appeal the assessee furn [LexDoc Id : 425444]
|
ITAT (Hyderabad) |
2012 |
Alpine Electronics Asia Pte Ltd. vs Director General of Income Tax and Ors.
Limitation for notice u/s 143(2) in re-assessment-Time-barred notice and S. 292BB-A.Y. 2003-04 to 06-07. The returns u/s 148 were filed after 1.10.2005. It was mandatory to issue and serve notice u/s 143(2) within period specified. [LexDoc Id : 422617]
|
HC (Delhi) |
2012 |
Vipin Enterprises vs ACIT
[LexDoc Id : 431993]
|
ITAT (Delhi) |
2012 |
ACIT vs Grindwell Norton Ltd.
Grindwell Norton Ltd. vs DCIT
[LexDoc Id : 423966]
|
ITAT (Mumbai) |
2012 |
Vodafone International Holdings B.V. vs UOI and Anr.
Income deemed to accrue in India-Gains from: offshore transactions Payment from No-Resident to non-resident Parent company & it’s subsidiary Tax avoidance & Tax planning v. colorable device-A. ANTI AVOIDANCE RULE-
While applying anti avoidance rule, the Revenue may invoke principle of, ‘substance over from’ or ‘piercing the corporat [LexDoc Id : 422281]
|
SC |
2012 |
AIA Engg. Ltd. vs Addl. CIT
Expenditure on exempt income-Working of disallowance by assessee-The assessee gave working of interest expenses and other indirect expenses covered u/s 14A. Without pointing out any mistake in that working no furthe [LexDoc Id : 424633]
|
ITAT (Ahmedabad) |
2012 |
Shell India Markets (P) Ltd., In re
FTS v. Business support services-Cost contribution Agreement-The applicant, an Indian co. entered into a cost contributions agreement with SIPCCL of U.K. The U.K. co. provided business support services like:- LexDoc Id : 424883]
|
AAR |
2012 |
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