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Ge India Industrial (P) Ltd.,, Haryana vs The Acit.,Kheda Circle,, Nadiad on 4 December, 2018

7.3. Our view is supported by ITAT judgments - Mumbai Bench in the cases of UCB India (P) Ltd. Vs. ACIT (supra); and ACIT v. Star India Ltd. (supra); and Kolkata Bench in the case of Development Consultants (P) Ltd. (supra). All these cases clearly lay down that ALP would be determined based on the nature of service provided by assessee for each class of transaction based on various factors and analysis.
Income Tax Appellate Tribunal - Delhi Cites 31 - Cited by 18 - Full Document

M/S. Development Consultants (P) Ltd., ... vs Dcit, C Ircle- 11, Kolkata, Kolkata on 15 February, 2017

7.3. Our view is supported by ITAT judgments - Mumbai Bench in the cases of UCB India (P) Ltd. Vs. ACIT (supra); and ACIT v. Star India Ltd. (supra); and Kolkata Bench in the case of Development Consultants (P) Ltd. (supra). All these cases clearly lay down that ALP would be determined based on the nature of service provided by assessee for each class of transaction based on various factors and analysis.
Income Tax Appellate Tribunal - Kolkata Cites 5 - Cited by 5 - Full Document

Acit 16 (1), Mumbai vs Star India Pvt. Ltd. (Sucessor Of Star ... on 20 June, 2023

7.3. Our view is supported by ITAT judgments - Mumbai Bench in the cases of UCB India (P) Ltd. Vs. ACIT (supra); and ACIT v. Star India Ltd. (supra); and Kolkata Bench in the case of Development Consultants (P) Ltd. (supra). All these cases clearly lay down that ALP would be determined based on the nature of service provided by assessee for each class of transaction based on various factors and analysis.
Income Tax Appellate Tribunal - Mumbai Cites 31 - Cited by 2 - Full Document
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