Section 92c - Judgment Search Results

Aztec Software and Technology Vs. Acit

Court: Income Tax Appellate Tribunal ITAT

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

..... that circumstances mentioned in clause a to d of sub section 3 of section 92c are satisfied once provisions of sub section 3 of section 92c are complied with the ao can consider whether it is ..... lead to a different meaning the procedure to determine alp in section 92ca is different from the one provided in section 92c under section 92c the assessing officer has himself to determine the alp whereas .....

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

Court: Delhi

..... as well as the assessing officer invoking power under sub section 3 to section 92c of the act as noted above sub section 2 to section 92c stipulates that most appropriate method out of the methods ..... to exercise the option under the first proviso to sub section 2 to section 92c and claim reduction similarly the first proviso to section 92c stipulates that where more than one price is determined by .....

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

Court: Mumbai

..... the caption refers to the proposed amendments in respect of section 92c not section 92ca and ends stating this amendment is proposed to ..... s length price in relation to an international transaction under section 92c to the transfer pricing officer at this juncture we may ..... to indicate that the computation of the total income under section 92c 4 and 92ca 4 is only with respect to international .....

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

Court: Income Tax Appellate Tribunal ITAT Delhi

..... and who is an associated enterprise has been defined in sections 92b and 92a respectively then arrives section 92c sub section 1 of this section provides that the arm s length price in relation ..... full power to determine the alp of the international transaction at his own sub section 3 of section 92c provides that where during the course of any proceedings for the assessment of income .....

Cargill India Pvt. Ltd. Vs. Dy. Commissioner of Income-tax

Court: Income Tax Appellate Tribunal ITAT Delhi

Reported in: (2008)300ITR223(Delhi)

..... made by the a o the tpo can use powers under section 92c and section 92d which are relayed to him for determining alp he has ..... in relation to the international transaction in accordance with sub section 3 of section 92c and send a copy of his order to the assessing ..... proceed to compute the total income of the assessee under sub section 4 of section 92c in conformity with the arm s length price as so .....

Morgan Stanley and Co. Vs. Dit(international Taxation)mumbai

Court: Authority for Advance Rulings

..... an order in writing determine the arms length price in accordance with sub section 3 of section 92c sub section 4 of section 92ca provides that on receipt of the order of the tpo the ..... power to determine arms length price in an international transaction is contained in sub section 3 of section 92c however section 92ca provides that where the assessing officer considers it necessary or expedient so .....

Commissioner of Income Tax Vs. Mentor Graphics (Noida) Pvt.Ltd.

Court: Delhi

..... relation to the international transaction in accordance with the provisions of sub section 1 and sub section 2 of section 92c on the basis of such material or information or documents available with ..... be tempered with the relevant statutory provisions which are clearly set out in sub section 3 of section 92c of the said act which stipulates four situations whereunder the assessing officer transfer .....

Sony India (P) Limited Vs. Deputy Commissioner of Income Tax

Court: Income Tax Appellate Tribunal ITAT Delhi

..... s length price in the light of sub section 1 and sub section 2 of section 92c of the i t act 160 after considering ..... tax act providing for determination of arm s length price under section 92c required that following steps are to be taken while applying ..... reason of dispute lies in divergent interpretations of the proviso to section 92c 2 of the act which contains relevant provisions dealing with such .....

Maruti Suzuki India Ltd. Vs. Commissioner of Income Tax

Court: Delhi

..... international transaction entered into by msil with smc in terms of section 92c of the act v while giving the above direction the ..... an international transaction shall be computed having regard to the alp section 92c 1 which sets out the different methods of determining the ..... one of the modes similar to the ones contemplated by section 92c may not only be legally impermissible but will lend itself .....

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

Court: Delhi

..... been determined by the assessing officer in terms of the provision of sub section 3 of section 92c 28 under section 92ca inserted w e f 1 6 2002 the ao is empowered to ..... to in addition read the definition of transaction given in section 92f v 27 section 92c is the provision enabling determination of alp section 92c 1 states that alp in relation to an international transaction .....