Google India (P) Ltd. vs DCIT
ALP - Software Development and I.T. Services-Tests for Selecting comparables - Functional comparables - Super profit companies-A.Y. 2006-07.
The assessee was in software development services and I.T. enabled services.
The TPO could not select super profit Companies a [LexDoc Id : 441510]
ITAT (Bangalore)
2012
ACIT vs Ckar Systems (P) Ltd.
ALP: Computation - Medical transcription services-CUP Method: Rejection of-A.Y. 2005-06.
The assessee provided medical transcription services to its foreign parent co. For ALP it applied CUP Method.
The A.O. could n [LexDoc Id : 437104]
ITAT (Hyderabad)
2012
DCIT vs J. Ray McDerrmott Eastern Hemisphere Ltd.
PE - Multiple contracts - Duration of a contract-Dates in contract-agreement v. Actual dates-A.Y. 1997-98.
The assessee a co. of Mauritius entered into 3 contracts in India. The period taken for all of the three exceeded 9 months.
Th [LexDoc Id : 437784]
ACIT vs Anil Kumar Jain
Business income v. Capital gains-Tests-A.Y. 2007-08.
The frequency, volume and regularity of dealing in shares would decide whether the income was from business or not.
For 15 Tes [LexDoc Id : 437873]
SKS Ispat and Power Ltd. vs CCE
Interpretation of statues: Clear legislative intention-Interpretation of statues: Clear legislative intention-When intention of the legislature was clear no process, which went against that intention, should be adopted. [LexDoc Id : 437398]
Adidas Sourcing Ltd. vs ADIT
FTS vis-à-vis commission for procuring goods-Payment to purchasing agent from abroad - Sourcing goods from abroad and marketing information etc.-A.Y. 2007-08.
The assessee was a Non-Resident Co. It provided services
to an Indian Co. for:-
- Sourcing of goods abroad;
- Maintainin [LexDoc Id : 436881]
Castrol India Ltd. vs ACIT
ALP-Computation of-I.T. Projects-A.Y. 2002-03.
Assessee belonged to a group which was in I.T. projects named, Common Operating Environment System (COES). The costs incurred in re [LexDoc Id : 441513]
Nokia Networks OY vs ADIT
Royalty: Supply of software-Supply of software as integral part of supply of hardware-The payment received for supply of software as an integral part of supply of equipment was not royalty either u/s 9(1)(vi) or under the DTAA.
S. [LexDoc Id : 435327]
HC (Delhi)
2012
Sonata Information Technology Ltd. vs DCIT
Income deemed to accrue or arise in India-Living allowance received from Indian co.-The technical personnel deputed by foreign co. received living allowance from Indian co. The allowance was paid directly to experts. This amount could [LexDoc Id : 434549]
