S. 127 : Power to transfer cases -SLP dismissed – Observations of High Court to have no reflection on merits.[S. 127(2), 132, 133A Art. 136, 226]
S. 127 : Power to transfer cases -SLP dismissed – Observations of High Court to have no reflection on merits.[S. 127(2), 132, 133A Art. 136, 226]
S. 92C : Transfer pricing-Arm’s length price -Adjustment on account of interest-free loans-Libor +2 Per Cent.-Corporate guarantee-Write-off of loss on account of investment in equity shares in subsidiary -Book profits -Provision for doubtful debts -No question of law -Order of High Court affirmed -SLP of Revenue is dismissed. [S. 92B, 115JB, Art. 136]
S. 92C : Transfer pricing -Arm’s length price -Support services -Cost plus model -Commission based model- Comparable –Question of fact. [Art. 136, 226]
S. 92C : Transfer pricing -Arm’s length price – Reasoned order based on cogent reasons-Order of High Court affirmed -Question of law left open. [S. 136, 260A]
S. 80IB : Industrial undertakings – derived from – Profits from Duty Entitlement Passbook Scheme and Duty Drawback claims- Not income “Derived From” Industrial Undertaking-Not eligible for deduction. [28(iiib), 28(iiic), Art, 136]
S. 80IA : Industrial undertakings-Telecommunication Services Change in shareholding-Block of ten consecutive years-Losses which have lapsed cannot be taken into account for purposes profits of undertaking. [S. 79, 80IA(5)]
S. 68 : Cash credits – Purchase and sale – Genuineness of the Transactions was established -Order of Tribunal deleting the addition was affirmed. [S. 37(1), 260A]
S. 50B : Capital gains -Slump sale -Sale of each asset -No liability was transferred -Not a Slump sale -Question of fact. [S.2(19AA), 2(42C), 45, 260A]
S. 50B : Capital gains -Slump sale -Sale of each asset -No liability was transferred-Not a Slump sale-Question of fact. [S. 2(19AA), 2(42C), 45, Art. 136]
S. 45 : Capital gains -Capital loss -Capital asset – Loan given to its subsidiary in India -Short-term capital loss —Order of High Court affirmed -SLP of Revenue dismissed. [S. 2(14), Art, 136]