Cognizant Technology Solutions India (P) Ltd. vs DCIT
Adjustment of refund against arrears of tax-Duty of A.O.-A.Y. 2008-09.
In case the A.O. wants to adjust the refund of tax against arrears of tax u/s 245, he must intimate the assessee in writing before [LexDoc Id : 443109]
Marubeni India (P) Ltd. vs DIT
ALP-Compensation for closure of Indian branches office-A.Y. 2002-03.
The compensation received for closure of Indian offices would not impact the fixation of ALP.
The compensation paid is abnorma [LexDoc Id : 445074]
CIT vs Cheil Communications India (P) Ltd.
Validity of: Re-asstt.-No addition on recorded reasons for re-opening-A.Y. 2006-07.
There was no addition made on basis of reasons u/s 148(2). The re-opening could not be upheld on another ground.
Expln. 3 to S [LexDoc Id : 445499]
KLM Royal Dutch Airlines vs DDIT
Income from: Air transport in international traffic-Income from: Ground handling services - Technical handling Services-A.Y. 2008-09.
Assessee a company of Netherland was engaged in air transport in international traffic. The income received from other Airlines in [LexDoc Id : 448212]
ITAT (Delhi)
2013
Zeppelin Mobile System GMBH vs Addl. DIT
Breach of guidelines under FEMA-Competent authority to take action-A.Y. 2007-08.
The assessee co. was incorporation in Germany. It had an Indian subsidiary 'ZE'. Some of the shares of 'ZE' were sold to 'SL' at Rs [LexDoc Id : 445656]
Tellabs India (P) Ltd. vs ACIT
Duty of TPO-Natural justice-Opportunity of being heard to assessee-A.Y. 2003-04, 2004-05.
Since the TPO did not provide an opportunity of being heard to assessee the case was remanded to A.O. who would make a ref [LexDoc Id : 457052]
CIT vs Mentor Graphics Noida (P) Ltd.
ALP - Selection of Comparables-Duty of Tribunal-A.Y. 2002-03.
The Tribunal accepted the comparables selected by assessee and rejected those of TPO. Further, it reduced the comparables to four.< [LexDoc Id : 444201]
CTCI Overseas Corpn. Ltd., In re
Rectification of mistake by AAR-Not following wrong precedent-The Authority while disposing an earlier application u/r. 19 of AAR (Procedure) Rules, 1996, expanded the scope of the expression "apparent from recor [LexDoc Id : 450042]