Search Results for "arm's length price"

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Search Results for "arm's length price"

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Supreme Court

Supreme Court Dismisses Department's Appeal in Permanent Establishment Tax Dispute Under India-Korea DTAA. Court Upholds ITAT's Finding of Permanent Establishment but Remands Profit Attribution for Fresh Assessment Due to Insufficient Material.

22 Jul 2020

The dispute arose from the taxability of income attributable to a permanent establishment set up in India by Samsung Heavy Industries Co. Ltd., a Sout...

Supreme Court

Supreme Court Allows Revenue's Appeal in Transfer Pricing Case — CBDT Instruction Not Mandatory. Assessing Officer's Power to Determine Arm's Length Price Under Section 92C(3) Upheld Despite Non-Reference to TPO.

13 Aug 2019

The case involves an appeal by the Principal Commissioner of Income Tax-4, Mumbai against the judgment of the Bombay High Court which dismissed the Re...

Supreme Court

Supreme Court Dismisses Revenue's Appeal in Income Tax Assessment Nullity Case Due to Amalgamation. Assessment in Name of Non-Existent Entity Held Void Despite Participation by Successor Company.

25 Jul 2019

The Supreme Court dismissed the appeal filed by the Revenue against the judgment of the Delhi High Court which had upheld the Income Tax Appellate Tri...

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