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TATA POWER SOLAR SYSTEMS LIMITED VS ASSISTANT COMMISSIONER OF INCOME TAX
BANGALORE TRIBUNAL, May 17, 2023

If margins of assessee with respect to its trading segment were accepted to be at arm's length by TPO, then no separate adjustment of AMP expenses could be made by treating...

Subject : AMP expenses
Legislation Referred To : Section 250, 143(3), 92CA(3), 40(a)(i)
In Favour Of : Assessee

DAAWAT FOODS LTD. & ANR. VS ASSISTANT COMMISSIONER OF INCOME TAX & ANR.
DELHI TRIBUNAL, May 04, 2023

Share of profit from the partnership is mere distribution of income and is already been taxed, hence provisions under section 14A are not attracted in such cases.

Subject : Income
Legislation Referred To : Section 10, 14A, 37, 28, 928
In Favour Of : Assessee

JEFFERIES LLC VS DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)
BOMBAY TRIBUNAL, Mar 28, 2023

Services provided by the group entities or holding company to its subsidiaries as support services to run their business effectively will not be considered as FTS or FIS...

Subject : Non residents
Legislation Referred To : Section 9(i)(vii), 2(24)(iva), 234A, 271(1)(c), 143(3)
In Favour Of : Assessee

PHILIPS INDIA LIMITED VS ASSISTANT COMMISSIONER OF INCOME TAX
KOLKATA TRIBUNAL, Mar 27, 2023

1. This appeal filed by the assessee is against the order of ACIT, Circle-12(2), Kolkata u/s. 143(3) r.w.s. 254, 144C(5) & 92CA(3) of the Income-tax Act, 1961...

Subject : Associated enterprises and international transactions
Legislation Referred To : Section 92C(2), 143(3), 144C
In Favour Of : Assessee

SAMSUNG C & T CORPORATION VS COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)
DELHI TRIBUNAL, Mar 24, 2023

At the time of exercise of jurisdiction under Section 263 on the date of issuance of show cause notice, admittedly, proceedings before AAR was pending on the issue of...

Subject : Revision
Legislation Referred To : Section 115A, 143(3), 153(1)(vii), 263
In Favour Of : Assessee

OYO HOTELS AND HOMES PRIVATE LIMITED VS DEPUTY COMMISSIONER OF INCOME TAX & ANR.
HIGH COURT OF DELHI, Mar 23, 2023

Refund can only be stalled if A.O. records his reasons in writing as to why the release of refund is likely to affect the interests of the Revenue and that this step of the...

Subject : Recovery
Legislation Referred To : Section139, 142(1), 143(1), 241A
In Favour Of : Assessee

PRINCIPAL COMMISSIONER OF INCOME TAX VS SPRINGER INDIA PVT. LTD.
HIGH COURT OF DELHI, Mar 15, 2023

Tribunal was conscious of the fact that the assessee could enter into the APA with CBDT only from AY 2013-14 thus, having regard to this limiting factor Tribunal thought it...

Subject : Transfer pricing adjustment and related issues
Legislation Referred To : Section
In Favour Of : Assessee

ADOBE SYSTEMS SOFTWARE IRELAND LTD. VS ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)
DELHI TRIBUNAL, Feb 28, 2023

Transactions between the assessee and its AE in Indian having been found to be at arm's length, no further profit can be attributed to the PE.

Subject : Arm’s length price and related issues
Legislation Referred To : Section 143(3), 144C(13), 234D, 244A, 274
In Favour Of : Assessee

ARICENT TECHNOLOGIES (HOLDINGS) VS ASSISTANT COMMISSIONER OF INCOME TAX & ANR.
HIGH COURT OF DELHI, Feb 27, 2023

Passing fresh assessment order pursuant to the Tribunal’s order dated 07.01.2016, is barred under the provisions to Section 153(3) and 153(4).

Subject : Writs
Legislation Referred To : Section10B, 143(3), 144C(13), 153(2A)
In Favour Of : Assessee

ASSISTANT COMMISSIONER OF INCOME TAX VS ITC INFOTECH INDIA LIMITED
KOLKATA TRIBUNAL, Oct 18, 2022

Overseas associated enterprise be accepted as the 'tested party' being the least complex of the transacting entity for the year for comparability analysis of international...

Subject : Tested party
Legislation Referred To : Section 144C, 143(3)
In Favour Of : Assessee