Search Results Page
Search Results
1 - 9 of 9 (0.27 seconds)Article 12 in Constitution of India [Constitution]
Article 5 in Constitution of India [Constitution]
Article 7 in Constitution of India [Constitution]
M/S Dit (International Taxation), ... vs M/S Morgan Stanley & Co. Inc on 9 July, 2007
12. We find the above view of the Ld. CIT(A) is not sustainable in the
light of the decision of the Hon'ble Supreme Court as above in the case of
DIT vs Morgain Stanley & Co.(supra).
Adobe Systems Software Ireland Ltd., ... vs Adit, New Delhi on 9 May, 2018
• Without prejudice to the above, of any additional
profits are required to be attributed, the same may be
done in the hands of Adobe India
> Without prejudice to the above, if the tax authorities
were to attribute any income in respect of the alleged
functions performed by the alleged PE of Adobe Ireland, it
may be made to the income of Adobe India. The aforesaid
approach has been accepted by the Hon'ble Delhi High Court
in the case of Adobe Systems Inc. v. ADIT (supra) (please
refer to pages 364 to 394 of the case law compilation).
Section 1 in The Indian Contract Act, 1872 [Entire Act]
Section 182 in The Indian Contract Act, 1872 [Entire Act]
Motorola Solutions Inc., Gurgaon vs Dcit, Circle- Gurgaon, International ... on 4 October, 2019
❖ It maybe noted that the Delhi ITAT in the case of
Motorola Inc. v. DCIT [2005] 95 ITD 269 (Delhi) (Special
Bench), had followed a similar methodology wherein the
global net profit percentage was applied to the Indian sales
and the resulting figure was further multiplied by 20% to
18 ITA No.5027/Del/2017 & Ors.
determine the attributable profits to the Indian PE. This
Methodology has been approved by this Hon'ble Tribunal in
the case of Ricardo UK Limited \ITA 4.QOQ/Del-2Qi8.
1