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Moser Baer India Ltd. Vs. the Additional Commissioner of Income Tax an ...

Court : Delhi

Subject : Direct Taxation

Acts : Finance Act, 2007 - Sections 4A, 92CA, 92CA(2), 92CA(3), 92CA(4) and 143(3); Income Tax Act, 1922 - Sections 42(2); Income Tax Act, 1961 - Sections 92 to 92F, 220(2A), 246A, 250(4), 271AA and 271(1); Finance Act, 2001 - Sections 92; Finance Act, 2007; Assam Municipal Corporation Act - Sections 298; Imports and Exports (Control) Act, 1947 - Sections 4M(1); Municipal Act - Sections 298; Income Tax Rules, 1962 - Rules 10A and 10B, 10D, 10E and 46A; Constitution of India - Articles 226 and 227

Reported in : (2009)221CTR(Del)97; [2009]316ITR1(Delhi); [2009]176TAXMAN473(Delhi)

enactment of Income Tax Act, 1961 a somewhat similar provision was inserted by way of Section 92. By Finance Act, 2001 w.e.f. 1.4.2002 Section 92 was substituted by Sections 92 to 92F; provisions which are contained in Chapter X

Sony India (P.) Ltd. Vs. Central Board of Direct Taxes and anr.

Court : Delhi

Subject : Direct Taxation

Acts : Income Tax Act, 1961 - Sections 16A, 55A, 92 to 92F, 119, 131(1), 133(6), 154(5) and 245E; Finance Act, 2001; Wealth Tax Act, 1957 - Sections 7; Income Tax Act, 1922 - Sections 23A; Constitution of India - Articles 14, 226 and 227

Reported in : (2006)206CTR(Del)157; [2007]288ITR52(Delhi)

high end products such as DVDs, Handy Cams, Play Stations and Projectors etc. for sale in India.3. The Finance Act, 2001 substituted the earlier Section 92 of the Income Tax Act 1961 ('Act') with Sections 92 to 92F with

Set Satellite (Singapore) Pte Ltd., a Company Incorporated and Registe ...

Court : Mumbai

Subject : Direct Taxation

Acts : Income Tax Act, 1961 - Sections 9, 92, 92C, 119, 195, 145, 234A, 234B and 234C; Finance Act, 2001; Finance Act, 2002

Reported in : (2008)110BOMLR2726; 2008BusLR850(Bom); (2008)218CTR(Bom)452; [2008]307ITR205(Bom)

price are contained in Section 92 of the Income Tax Act. The principles have been clarified by the Finance Act, 2001 as also Finance Act, 2002. From the order of the C.I.T. which has been accepted it is clear

Slocum Investment P. Ltd. (Now Vs. the Deputy Commissioner of Income

Court : Income Tax Appellate Tribunal ITAT Delhi

Subject : Service Tax

is also pertinent to note that the original Section 92 was substituted by a new Section by the Finance Act, 2001 with effect from 1st April, 2002 and before this new Section becomes operative from that date, the same

Slocum Investment (P) Ltd. Vs. Deputy Commissioner of Income Tax

Court : Income Tax Appellate Tribunal ITAT Delhi

Subject : Service Tax

Reported in : (2006)101TTJ(Delhi)558

is also pertinent to note that the original Section 92 was substituted by a new section by the Finance Act, 2001 w.e.f. 1st April, 2002 and before this new section becomes operative from that date, the same again came

Dit (international Taxation), Mumbai Vs. Morgan Stanley and Co. Inc.

Court : Supreme Court of India

Subject : Direct Taxation

Acts : Income Tax Act, 1961 - Sections 10A, 10B, 44BB, 44BBA, 92 to 92E and 92F; Finance Act, 2001; Finance Act, 2002; Income Tax Rules - Rule 10A to 10E

Reported in : (2007)109BOMLR1348; 2007BusLR58(SC); (2007)5CompLJ21(SC); (2007)210CTR(SC)419; [2007]292ITR416(SC); JT2007(9)SC1; 2007(9)SCALE1; (2007)7SCC1;

of P.E. was introduced in 1961 Act as part of the statutory provisions of transfer pricing by the Finance Act of 2001. In Section 92-F(iii) the word 'enterprise' is defined to mean 'a person including a P.E. of

M/S. L.G. Electronics India Private Limited Vs. the Asstt. Commissione ...

Court : Income Tax Appellate Tribunal ITAT Delhi

Subject : Direct Taxation

the context of sec. 92 as it existed before its substitution by sec. 92 to 92F by the Finance Act, 2001, being the transfer pricing provisions under consideration. It was however, maintained that the ratio decidendi of these decisions … 15.1. At this stage, we feel it productive to have a macro view of the transfer pricing provisions. Section 92 provides that the income from an international transaction shall be computed having regard to ALP. What is an

Aztec Software and Technology Vs. Acit

Court : Income Tax Appellate Tribunal ITAT

Subject : Direct Taxation

Reported in : (2007)107ITD141(Bang.)

manipulating prices charged or paid in international transactions, thereby eroding the country's tax base.4. Accordingly, legislative changes through Finance Act, 2001 and 2002 were made. It was provided in Section 92(1) that income arising from international transaction between associated

In Re: Instrumentarium

Court : Authority for Advance Rulings

Subject : Direct Taxation

Reported in : (2005)193CTRAAR347

transfer pricing were first introduced by substituting Sections 92 to 92F for the then existing Section 92 by Finance Act, 2001; however, they were also substituted by new set of provisions-ss. 92 to 92F- by the Finance Act, 2002,

Director of Income Tax (international) Taxation Vs. Oman International ...

Court : Mumbai

Subject : Direct Taxation

Acts : Direct Tax Laws (Amendment) Act, 1987 - Sections 28, 36, 36(1) and 36(2); Finance Act, 2001

Reported in : 2009(5)BomCR416; (2009)223CTR(Bom)382; [2009]313ITR128(Bom); [2009]184TAXMAN314(Bom)

thereof exceeds the credit balance in the provision for bad and doubtful debts account made under that clause.The Finance Act, 2001 inserted the following Explanation after the proviso to Section 36(1(vii):Explanation - For the purposes of this clause, any … Competent officials of the bank, the same has to be allowed as a deduction and accordingly allowed Rs. 92,96,000/- as bad debts which were disallowed by the A.O. Appeal was partly allowed.3. Revenue aggrieved by the order