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M/S. Vodafone India Service Pvt. Ltd., (Formerly Known as 3 Global Ser ...

Court : Mumbai

Subject : Direct Taxation

in respect of any person or class of persons.]” Sub-section (2A) of Section 92CA was introduced by the Finance Act, 2011 with effect from 1st June, 2011. Sub-section (2B) was introduced by the Finance Act, 2012 with retrospective … granted a right to subscribe to the shares in respect of the group companies. 6. On 11th February, 2007, a share purchase agreement (hereinafter referred to as the “SPA”) was entered into between HTIL and Vodafone International … hold any opinion which my lead to your recommending any adjustments under chapter X of the Act, having regard to the various documents submitted by … agreements as a confirming party. Proceedings before respondent Nos.2 and 3 : 10. This brings us to the demands made by the respondents upon the

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)

to be invariably complex. It was his submission that prior to the amendment brought about by virtue of Finance Act, 2007, w.e.f. 1.6.2000, the assessee was afforded an opportunity of presenting its case, both before the TPO, as well … ALP determined by the assessee, it could proceed to determine, the same in accordance with the provisions of Chapter X of the Act. It is the contention of the learned Counsel for the petitioners, that in the … determining the most appropriate method, regard is to be had to Rules 10A and 10B of the Income Tax Rules, 1962 (in short the 'Rules').Sub-section

Essar Steel Ltd. Vs. Union of India (Uoi)

Court : Gujarat

Subject : Customs

Acts : Finance Act, 2007 - Sections 99 and 114; Customs Act, 1962 - Sections 7, 12, 22, 25, 28(1), 30 and 76A to 76N; Sea Customs Act; Special Economic Zones Act, 2005 - Sections 1, 2, 2(1), 3, 3(1), 4, 4(1), 4(2), 4(4), 5, 7, 12, 15(9), 26, 26(1), 26(2), 30, 51, 53, 53(1), 53(2) and 55; Motor Vehicles Act - Sections 38 and 38(1); Taxation Act - Sections 3, 3(1) and 4A; Trade Marks Act - Sections 28; Uttar Pradesh Trade Tax Act, 1948 - Sections 3; Central Excise Act, 1944 - Sections 4 and 4(1); Factories Act, 1948; Sea Customs (Amendment) Act, 1955; Land Customs Act; Indian Aircrafts Act, 1911; Customs Tariff Act, 1975 - Sections 2, 2(15), 2(18), 2(19), 2(20), 2(22), 2(23), 2(25), 2(26), 2(27), 12, 14, 14(1), 17, 18, 46 and 50; Industries (Development and Regulation) Act, 1951; Income

Reported in : [2010]24STT121

permitted the goods into the zone. By virtue of Section 114(n) read with the 3rd Schedule to the Finance Act, 2007, Heading No. 11 of the Second Schedule - Export Tariff to the Customs Tariff Act, 1975 was substituted … Section 2(27) to include the territorial waters of India. Mr. Champaneri further submitted that Section 12 contained in Chapter V of the said Act provides that except as otherwise provided in the said Act, or any other … the goods to SEZ Units.4. In Special Civil Application Nos. 9656, 9713, 10444, 10445, 10446, 13298, 11032 and 11909 of 2008, Mr. K.S. Nanavati and

Swapan Kumar Pal Vs. Oil and Natural Gas Corporation Ltd. and ors.

Court : Guwahati

Subject : Service Tax

On the basis of the same NIT further work orders were also issued in subsequent years.2. Under the Finance Act, 1994, Chapter V was inserted introducing the concept of 'service tax'. Cab providers were also brought within the … a sum of Rs. 62,476 on account of service tax for the period from November, 2006 to January, 2007 and this was reimbursed by the ONGC through cheque dated March 31, 2007. However, the ONGC has not … was issued on the basis of NIT dated February 22, 2002. Clause 10 of the said NIT deals with tax liability and Clause 10.2 relates

Li and Fung India Pvt. Ltd. Vs. Commissioner of Income Tax

Court : Delhi

Subject : Land Acquisition

time frame within which the TPO has to pass an order under Section 92CA (3).29. Prior to the Finance Act, 2007, Section 92CA (4) read as follows:“On receipt of the order under sub-section (3), the Assessing Officer shall proceed … so as to ensure certainty in these calculations rather than roving enquiries.25. Specifically, the object behind introduction of Chapter X of the IT Act was to prevent assessees from avoiding payment of tax by transferring income yielding … to The risk matrix as disclosed in transfer pricing report under Rule 10D Capacity utilization risk Disclosed in transfer pricing report Page 7 4. Disclosed

M/s. Bharti Airtel Ltd. Vs. The Commissioner of Central Excise

Court : Mumbai

Subject : Service Tax

Secondary and Higher Education Cess on excisable goods leviable under section 136 read with section 138 of the Finance Act, 2007 (22 of 2007);(vii)(vii) the additional duty leviable under section 3 of Customs Tariff Act, equivalent to the duty … nor the use of said goods in providing output service. Subsequently, information about use of the goods and Chapter heading under the Central Excise tariff was called for from the appellant. The same was, thereafter, furnished by … on the Credit Rules introduced by the Central Government with effect from 10.9.2004 and more particularly Rule 3(1) which defines the term “Cenvat Credit”, Rule

Sony Ericsson Mobile Communications India Pvt. Ltd Vs. Commissioner of ...

Court : Delhi

Subject : MRTP

A comparable would be an unrelated identity with similar distribution and marketing functions.125. The United Nations‘ Manual in Chapter 10 relating to country specific practices notes the Indian stand, but records that the first nine chapters of the … the Assessing Officer, having regard to retrospective amendment to Section 92CA of the Income Tax Act, 1961 by Finance Act, 2012.2. Whether AMP Expenses incurred by the assessee in India can be treated and categorized as an international … Canon India Pvt. Ltd Daikin Air Conditioning (India) Pvt. Ltd 132/2014 214/2014 2007-08 2008-09 2006-07 2007-08 2008-09 2007-08 2008-09 93/2014 99/2014 100/2014 101/2014 109/2014 512/2014

Dharampal Satyapal Limited. Vs. Union of India

Court : Guwahati

Subject : Education

negative list of ineligible industries in furtherance of such objective. It also referred to Section 154 of the Finance Act,2003 read with Schedule IX thereto vis-a-vis the products enumerated therein to and also sought to reinforce its stand … exemption from payment of excise duty on its finished goods, the North East Industrial and Investment Promotion Policy, 2007 (for short referred to as the Policy, 2007) was promulgated vide Office Memorandum No.10(3)/2007-DBA-II/NER dated 01.04.2007 by the … Eastern Region with effect from that date categorized pan masala covered under Chapter 21 of the First Schedule to the Central Excise Tariff Act,1985 (hereinafter

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

Court : Income Tax Appellate Tribunal ITAT Delhi

Subject : Direct Taxation

called `the Act') has undergone certain changes. He referred to sub-section (2A) of section 92CA, inserted by the Finance Act 2011 w.e.f. 1-6-2011, as per which, where any other international transaction, apart from those referred to under sub- … TPO during the course of proceedings before him, the provisions of this Chapter shall apply as if such international transaction is an international transaction referred … it is only academic in so far as we are concerned with the present appeal involving the A.Y. 2007-08, which is a period anterior to A.Y. 2012-13. The extant case is fully and directly covered under sub- … subsidiary of LGK. An agreement was entered between LGK and LGI on 10th March 1997, as per which both entered into a mutual foreign collaboration

Coca Cola India Inc. Vs. Assistant Commissioner of Income Tax and ors.

Court : Punjab and Haryana

Subject : Direct Taxation

Reported in : (2009)221CTR(P& H)225; [2009]309ITR194(P& H); [2009]177TAXMAN103(Punj& Har)

submitted that opportunity had become all the more necessary in view of amendment w.e.f. 1st June, 2007 vide Finance Act, 2007, amending Section 92CA(4) of the Act to the effect that order of the TPO would be final and … Adarsh Kumar Goel, J.1. This petition questions application of transfer pricing provisions in Chapter X of the IT Act, 1961 (for short, 'the Act') to the petitioner and quashing of notices under … having regard to the ALP so determined:Provided that no deduction under Section 10A or Section 10AA or Section 10B or under Chapter VI-A shall be