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Unknown vs The Dispute Resolution Panel (Drp) on 11 June, 2021 cites

Dongfang Electric (India) Private ... vs D.C.I.T., Circle - 14(1), Kolkata, ... on 27 March, 2019

35. The decision of the Tribunal in Dongfang Electric Corporation Vs Deputy Commissioner of Income Tax, (referred to supra) relied upon by the learned counsel for the petitioner is also distinguishable. There, repeated opportunity was given to the Income Tax Department to produce any letter to prove that the Assessing Officer had made a reference of the International Transaction to the Transfer Pricing Officer. What was produced before the Income Tax Appellate Tribunal was an approval of the Director of Income Tax(IT) dated 27.12.2011 for the Assessment Year 2009-2010. On facts, it was held https://www.mhc.tn.gov.in/judis/ 19/24 W.P. No.22901 of 2010 that the letter of approval signed by the I.T.O (tech) International Taxation did not meet the requirements of Section 92CA(1) of the Income Tax Act, 1961, which specifically requires reference by the Assessing Officer to the Transfer Pricing Officer, for computation of the Arm's-Length Price in relation to International Transactions. These considerations are not applicable to the facts of the case. That apart, the decision of the Income Tax Appellate Tribunal is not binding on this Court, although the ratio laid therein may have persuasive value. Therefore, I am unable to agree with the contention of the learned senior counsel for the petitioner.
Income Tax Appellate Tribunal - Kolkata Cites 9 - Cited by 1 - Full Document

State Of Punjab & Ors vs M/S Shreyans Indus.Ltd.Etc on 4 March, 2016

30. Thus, there is nothing in the provision which limits the reference to be made before the expiry period of 21 months wherever provisions of Section 92C or 92CA of the Income Tax Act, 1961 are attracted. The reference to the decision of the Hon'ble Supreme Court in the case of State of Punjab and others vs Shreyans Industries Limited and others, (2016) 4 SCC 769 is therefore distinguishable on facts and not appliable to the facts of the present case.
Supreme Court of India Cites 24 - Cited by 21 - A K Sikri - Full Document

Pandurang Dhoni Chougule vs Maruti Hari Jadhav on 26 April, 1965

(xx) Zuari Estate Vs Regional Director, ESIC, (2015) 7 SCC 690 (xxi) Pandurang Chogule Vs Maruti Hari Jadhav, (1966) 1 SCR 102 (xxii) Kalyankumar Ray Vs CIT, Calcutta, AIR 1992 SC 15 (xxiii) Auto & Metal Engineers and Ors., Vs Union of India and Ors., 1998 229 ITR 399 SC (xxiv) Bansilal Sons Vs ACIT, Nashik, [2019] 101 taxmann.com 20/260 Taxman 281 (Bom.)
Supreme Court of India Cites 4 - Cited by 200 - P B Gajendragadkar - Full Document

K.P. Varghese vs The Income Tax Officer,Ernakulam, And ... on 4 September, 1981

(xxviii) K.P.Varghese Vs Income-tax Officer, [1981] 7 Taxman 13 (SC) (xxix) UCO Bank Vs Commissioner of Income-tax, [1999] 104 Taxman 547 (SC) (xxx) UTI Mutual Fund Vs Income-tax Officer, [2013] 31 taxmann.com 222 (Bombay) (xxxi) UOI & Ors. Vs Kaumudini Dayal & Anr, (2001) 10 SCC 231 (xxxii) The Commissioner of Income Tax Vs Tata Autocomp Systems Ltd., ITA No.1320 of 2012 (xxxiii) The Commissioner of Income Tax-I, Mumbai Vs Alstom Projects India Limited, ITA No.362 of 2014 (xxxiv) CIT Vs JK Charitable Trust, (2009) 1 SCC 196 (xxxv) Nokia India Private Limited Vs Additional Commissioner of Income Tax and Ors., (2018) 301 CTR (Del) 665 (xxxvi) Javer Jivan Mehta Vs Assistant Commissioner of Sales Tax (Appeals), VIII Circle and Ors, [1998]111 STC 199 (Guj) (xxxvii) Savitri Rani Malik Vs Commissioner of Income Tax, (1991) 93 CTR (Gau) 163 (xxxviii) T.N.Dadha Pharmaceuticals Vs Collector of Central Excise, Madras, AIR 2003 SC 1556 https://www.mhc.tn.gov.in/judis/ 8/24 W.P. No.22901 of 2010 (xxxix) MIOT Hospitals Ltd., Vs The State of Tamil Nadu and Ors., [2020] 78 GSTR 299 (Mad) (xxxx) Peeru Lal, Mohan Lal Vs Commissioner of Income-tax, [2002] 124 Taxman 316 (Rajasthan) (xxxxi) ACIT Vs Hotel Blue Moon, [2010] 188 Taxman 113 (SC) (xxxxii) CIT Vs Gitson Engineering, [2015] 53 taxmann.com 108 (Madras).
Supreme Court of India Cites 26 - Cited by 3460 - P N Bhagwati - Full Document

Miot Hospitals Ltd vs The State Of Tamil Nadu on 28 May, 2020

(xxviii) K.P.Varghese Vs Income-tax Officer, [1981] 7 Taxman 13 (SC) (xxix) UCO Bank Vs Commissioner of Income-tax, [1999] 104 Taxman 547 (SC) (xxx) UTI Mutual Fund Vs Income-tax Officer, [2013] 31 taxmann.com 222 (Bombay) (xxxi) UOI & Ors. Vs Kaumudini Dayal & Anr, (2001) 10 SCC 231 (xxxii) The Commissioner of Income Tax Vs Tata Autocomp Systems Ltd., ITA No.1320 of 2012 (xxxiii) The Commissioner of Income Tax-I, Mumbai Vs Alstom Projects India Limited, ITA No.362 of 2014 (xxxiv) CIT Vs JK Charitable Trust, (2009) 1 SCC 196 (xxxv) Nokia India Private Limited Vs Additional Commissioner of Income Tax and Ors., (2018) 301 CTR (Del) 665 (xxxvi) Javer Jivan Mehta Vs Assistant Commissioner of Sales Tax (Appeals), VIII Circle and Ors, [1998]111 STC 199 (Guj) (xxxvii) Savitri Rani Malik Vs Commissioner of Income Tax, (1991) 93 CTR (Gau) 163 (xxxviii) T.N.Dadha Pharmaceuticals Vs Collector of Central Excise, Madras, AIR 2003 SC 1556 https://www.mhc.tn.gov.in/judis/ 8/24 W.P. No.22901 of 2010 (xxxix) MIOT Hospitals Ltd., Vs The State of Tamil Nadu and Ors., [2020] 78 GSTR 299 (Mad) (xxxx) Peeru Lal, Mohan Lal Vs Commissioner of Income-tax, [2002] 124 Taxman 316 (Rajasthan) (xxxxi) ACIT Vs Hotel Blue Moon, [2010] 188 Taxman 113 (SC) (xxxxii) CIT Vs Gitson Engineering, [2015] 53 taxmann.com 108 (Madras).
Madras High Court Cites 84 - Cited by 1 - C Saravanan - Full Document
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