Search Results Page
Search Results
1 - 8 of 8 (0.32 seconds)Vodafone India Services Pvt. Ltd vs Union Of India, Ministry Of Finance And ... on 10 October, 2014
It is obvious that the facts of the instant case
are absolutely different from those considered in the case of Vodafone
India Services Pvt. Ltd. (supra).
Finance Act, 2012
Section 144C in The Income Tax Act, 1961 [Entire Act]
Cit vs Agnity India Technologies Pvt Ltd on 10 July, 2013
It is further noticed that the Hon'ble Delhi High
Court in CIT Vs. Agnity India Technologies (P.) Ltd. (2013 ) 219
Taxman 26 (Del) examined the comparability of Infosys Technologies
26
ITA No.240/Del/2015
from the angle of its inclusion or otherwise in the list of comparable of
Agnity India Technologies, a captive unit providing ITES to its AE
alone. In that case, the TPO treated three companies as comparable,
namely, Satyam Computer Service Ltd., L&T Infotech Ltd. and Infosys
Technologies. The DRP excluded Satyam Computer only. The Tribunal
excluded only Infosys Technologies Ltd., by impliedly retaining L&T
Infotech Ltd. as a good comparable. On appeal by the Revenue, the
Honourable High Court upheld the Tribunal order excluding Infosys on
the strength of certain relevant distinguishing features including its
giantness in terms of sales, nature of work and other factors. Thus it
follows that L&T Infotech Ltd., which is otherwise a vast company with
much higher turnover, finally found the status of a comparable with a
captive company providing ITES to its AE alone.
The Income Tax Act, 1961
Commissioner Of Income Tax-I vs M/S Cotton Naturals (I) Pvt. Ltd. on 27 March, 2015
In so far as the question of rate of interest is concerned, we find
that this issue is no more res integra in view of the judgment of the
Hon'ble jurisdictional High Court in the case of Cotton Naturals (I) Pvt.
Ltd. (supra), in which it has been held that it is the currency in which
the loan is to be repaid which determines the rate of interest and hence
50
ITA No.240/Del/2015
the prime lending rate should not be considered for determining the
interest rate. Under such circumstances, we set aside the impugned
order and remit the matter to the file of TPO/AO for a fresh
determination of addition on account of transfer pricing adjustment
towards interest not realized from its AE on the debts arising during the
course of business in line with our above observations.
C.I.T-Ii Pune vs M/S Patni Computer System Ltd. on 17 October, 2014
13.7. The Hon'ble Bombay High Court in the case of CIT vs. Patni
Computer Systems Ltd., (2013) 215 Taxmann 108 (Bom.) dealt, inter
alia, with the following question of law:-
1