Section 92

Section 92, Sec. 260A, Section 260, Section 92CA

Karnataka H.C : Whether on the facts and in the circumstances of the case, the Tribunal is right in law in directing the AO/TPO to confine Arms Length Adjustment to the value of international transactions in the manufacturing segment of the assessee by relying on the decision of it in case of assessee itself which has not reached finality without appreciating that TPO has chosen TNMM method as the most appropriate method for determinate ion of ALP with regard to the manufacturing segment and has accepted same comparable as selected by assessee for bench marking analysis?

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High Court Of Karnataka Pr.CIT & Anr vs. Products India Automotive Pvt. Ltd Section 92CA, 260-A Asst. Year 2010-11 Dr. […]

Sec. 260A, Section 253, Section 92, Section 94

Karnataka H.C : Whether on the facts and in the circumstances of the case the Tribunal is right in law rejecting comparables namely, Kais Information systems Lid, Tata Elxsi Ltd. M/s. Accel Information Systems Ltd, M/s. Bodhtree Consulting by following its earlier order and without appreciating that the reasonings of TIO/Ah) for adopting the said comparables which have been brought out in the TPO’s order and without appreciating that TPO has chosen the same after application of mind and materials on record”?

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High Court Of Karnataka Pr.CIT vs. Softbrands India P. Ltd. Section 260-A, 92 to 94-B, 253 Asst. Year 2006-07 Vineet

Section 92

Madras H.C : Where any person, being the assessee, has entered into an international transaction in any previous year, and the Assessing Officer considers it necessary or expedient so to do, he may, with the previous approval of the Commissioner, refer the computation of arm’s length price in relation to the said international transaction under Section 92C to the Transfer Pricing Officer.

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High Court Of Madras CIT vs. Same Deutz-Fahr India (P) Ltd. Section 92 Asst. Year 2006-07 Indira Banerjee, CJ &

Sec. 260A, Sec. 271(1)(c ), Sec. 92C(4), Sec. 92D, Section 10A, Section 10AA, Section 10B, Section 271, Section 92, Section 92C, Section 92CA

Punjab & Haryana H.C : Whether, the order of the Tribunal is perverse for non-consideration of relevant material, the evidence placed on record and submissions made by the Appellant and reaching a conclusion that the services availed were in the nature of shareholder activities and that the benefit received by appellant was only incidental and passive association benefit

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High Court Of Punjab & Haryana Knorr-Bremse India Pvt. Ltd. & Anr. vs. ACIT & ANR. S.J. Vazifdar, ACJ &

Sec. 260A, Sec. 144C, Sec. 271(1)(c ), Sec. 92D, Section 10A, Section 10AA, Section 10B, Section 37, Section 92, Section 92C, Section 92CA

Punjab & Haryana H.C : the evidence placed on record and submissions made by the Appellant and reaching a conclusion that the services availed were in the nature of shareholder activities and that the benefit received by appellant was only incidental and passive association benefit

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High Court Of Punjab & Haryana Knorr-Bremse India Pvt. Ltd. & Anr. vs. ACIT & ANR. S.J. Vazifdar, ACJ &

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