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1 - 9 of 9 (0.22 seconds)Section 92C in The Income Tax Act, 1961 [Entire Act]
Section 80HHE in The Income Tax Act, 1961 [Entire Act]
The Income Tax Act, 1961
Aztec Software And Technology Service ... vs Acit on 12 July, 2007
As noted in the case of Aztech Software (supra) "rarely one is able to locate an identical uncontrolled transaction". The Arms' Length Price is determined by taking result of a comparable transaction in comparable circumstances and by making suitable adjustments for the differences.
Indian Companies Act, 1913
M/S Dit (International Taxation), ... vs M/S Morgan Stanley & Co. Inc on 9 July, 2007
In the case of DIT (International taxation) v. Morgan Stanley 292 ITR 416, the Hon'ble Supreme Court after considering relevant Indian regulations on transfer pricing made some pertinent observations which are noted as under:
Parashuram Pottery Works Co. Ltd vs Income Tax Officer, Circle-1, Ward 'A', ... on 16 November, 1976
47. Before close, we would like to draw attention to the following observation of the Supreme Court in the case of Parashuram Pottery Works Co. Ltd. v. ITO wherein it was observed as under:
Legato Systems India (P) Ltd. vs Income Tax Officer on 30 November, 2004
48.1 The aforesaid decision is directed to be applied in the year under consideration as facts and circumstances as also objection of the revenue are similar as raised in that year. Besides, it may be pointed out that decision of the Tribunal in the case of Legato Systems (supra) has been approved by the Hon'ble Delhi High Court.
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