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Whether any TDS obligation arises on payments remitted to commission agents for procuring sales order abroad
KHIMJI VISRAM AND SONS Vs. ADDL. CIT
(2014) TaxCorp(LJ) 4208 (ITAT-MUMBAI) · Income Tax - Sections 9(1)(vii), 40(a)(i), 143(3), 154, 195
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Whether where a company is earning extraordinary profits in the course of its business, can the same is liable to be excluded from the list of comparables for purpose of determination of ALP
STREAM INTERNATIONAL SERVICES PVT LTD. Vs. ACIT
(2014) TaxCorp(LJ) 4207 (ITAT-MUMBAI) · Income Tax - Sections 92C(1), 144C(5)
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Whether when the comparable selected is functionally similar, there is any merit in the assessee's plea for its exclusion
M/s EVONIK INDIA PVT LTD. Vs. DCIT
(2014) TaxCorp(LJ) 4206 (ITAT-MUMBAI) · Income tax - Sections 92C(2), 143(3), 144C(5) & (13), 234B, C & D
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Whether where any miscellaneous income is earned on account of guarantee commission waived by the AEs of the assessee and such waiver consisted of day to-day operations of the assessee which was consistent with the accounting standards and policies, such income should be considered as operating income
M/s PETRO ARALDITE PVT LTD. Vs. DCIT
(2014) TaxCorp(LJ) 4205 (ITAT-MUMBAI) · Income tax - Sections 92D(1), 143(3), 144C(13)
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Whether when the case of payments made against rendering of technical services by the AE was remanded by the Tribunal in the previous AY, a similar TP adjustment is required to be made in the instant year.
VA TECH ESCHER WYSS FLOVEL PVT LTD. Vs. DCIT
(2014) TaxCorp(LJ) 4204 (ITAT-DELHI) · Income Tax - Sections 14A, 143(3), 144C
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Whether when operating margin trends of the said concern over the five financial years suggests a wide fluctuation, the same can be excluded from the list of comparables
CUMMINS TURBO TECHNOLOGIES LTD. Vs. DDIT
(2014) TaxCorp(LJ) 4203 (ITAT-PUNE) · Income Tax - Section 92CA
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Issue of shares at premium by Indian entity to holding company does not give rise to any income from international transaction
VODAFONE INDIA SERVICES PVT LTD Vs UoI
(2014) TaxCorp(LJ) 4202 (HC-BOMBAY)
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Whether the principle of proportionality is a well established principle in the jurisprudence of transfer pricing adjustments
DINA SUDHIR SHAH Vs. ACIT
(2014) TaxCorp(LJ) 4201 (ITAT-MUMBAI) · Income Tax - Section 92CA
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Whether when the entire job is sub-contracted to the AE being the lowest bidder, on back to back basis, the TPO is right in making TP adjustment with respect to excess costs without selecting any comparables
M/s INTERNATIONAL METRO CIVIL CONTRACTORS Vs. ACIT
(2014) TaxCorp(LJ) 4200 (ITAT-MUMBAI)
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Whether when the technical experts of the assessee render technical services in India, any consideration received in this regard is to be taxed in the country of source only to the extent of such amounts attributable to the activities performed in India
CIT. Vs. M/s VOEST ALPINE A G
(2014) TaxCorp(LJ) 4199 (HC-DELHI)
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HC set aside order rejecting Stay of demand in high-pitched assessments
CHARU HOME PRODUCTS PVT LTD. Versus COMMISSIONER OF INCOME TAX-1, NEW DELHI and ORS.
(2014) TaxCorp(LJ) 4198 (HC-DELHI)
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If AO not satisfied with correctness of expenditure claimed, he has to proceed in manner prescribed in Rule 8D(2)
Dhampur Sugar Mills Ltd. Vs. Commissioner Of Income Tax
(2014) TaxCorp(LJ) 4197 (HC-ALLAHABAD)
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Since assessment made u/s 143(3), no notice can be issued without satisfaction of CCIT/CIT – S. 151(1)
M/S Reliable Finhold Limited Vs. Union Of India And Anr.
(2014) TaxCorp(LJ) 4196 (HC-ALLAHABAD) · Sections. 143(3), 151(1)
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Whether the principles of mutuality will override the specific deeming provision of Sec 9(1)(v)
BANK OF TOKYO MITSUBISHI UFJ LTD. Vs. ADIT
(2014) TaxCorp(LJ) 4195 (ITAT-DELHI) · Income tax - Sections 9(1)(v)(c), 37, 40(a)(i), 44C, 90, 115JB, 144C(1) & (5), 205, 234B
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Whether conditions as to existence of PE and nexus of the contract with such a PE are indespensible for determining taxability of any payment made in relation to such contract u/s 44BB
SIEM OFFSHORE AS Vs. ADIT
(2014) TaxCorp(LJ) 4194 (ITAT-DELHI) · Income tax - Sections 5(2)(b), 9(1)(vii), 28, 44BB
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Whether when some remittances were made in the form of inter-bank transfers, it can be said that such remittances will attract penalty provisions for contravention of FERA, even if the identity of the source of income was not examined by the enforecment directorate
S K MITTAL Vs. ENFORCEMENT DIRECTORATE
(2014) TaxCorp(LJ) 4193 (HC-DELHI) · Foreign Exchange Regulation Act, 1973 (FERA) - Sections 6(4), 6(5) 8(1), 9(1)(a), 9(1)(f)(i)
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Whether as a thumb rule, depreciation has to be included before computing profit margins, irrespective of the fact whether it has any bearing on such margins or not
SIEMENS HEALTHCARE DIAGNOSTICS LTD. Vs. ACIT
(2014) TaxCorp(LJ) 4192 (ITAT-AHMEDABAD) · Income Tax – Sections 43B, 92CA
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Whether when no service is provided by the selling agent within the taxable territory in India, any disallowance u/s 40(a)(ia) can be made for the failure of deduct tax at source u/s 195
DCIT. Vs. TRANSFORMERS & ELECTRICALS KERALA LTD.
(2014) TaxCorp(LJ) 4191 (ITAT-COCHIN) · Income Tax - Sections 5, 9(1), 40(a)(ia), 143(3), 147, 148, 195, 200
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Whether it can be inferred that the remaining balance of operating cost is related to international transaction with other entities, when MAP resolution shows 92% of the operating cost with its holding company
M/s VIRTUSA INDIA PVT LTD. Vs. DCIT
(2014) TaxCorp(LJ) 4190 (ITAT-HYDERABAD) · Income Tax - Sections 10A, 90, 92C, 143(3), 154
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Whether any payments made to the non-resident news agency for photo news carried along with news reports are royalty, taxable under Sec 9(1)(vi) as well as Article 13 of the DTAA
AGENCE FRANCE PRESSE Vs. ADIT
(2014) TaxCorp(LJ) 4189 (ITAT-DELHI) · Income tax - Section 9(1)(vi)
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