section (3), the Assessing Officer shall proceed to compute the total income of the assessed under Sub-section (4) of Section 92C having regard ... done by the TPO under Sub-section (3) of Section 92CA read with Sub-section of Section 92C , the computation of total income having regard
provides for provisions relating to
computation of ALP. Sub-section (1) of Section 92C of the Act provides for
the methods of computing ... section (2) of Section 92C of the
Act mandates that the most appropriate method that has been referred to in
Section 92C(1) be applied
prior to making a reference under Section 92CA of the Act has to be
read into Section 92C A (1) in a case where ... international transaction or specified
domestic transaction in accordance with sub-section (3) of Section
92C and send a copy of his order to the Assessing
determining the
AMP can be a combination of methods prescribed under Section 92C(1)
was devoid of force. On a plain reading of Section 92C ... international transaction
entered into by MSIL with SMC in terms of Section 92C of the Act.
(v) While giving the above direction, the Division Bench
Section
92 (1) which states that any income arising from an international transaction
shall be computed having regard to the ALP and Section 92C ... purposes of this section and sections
92 , 92C , 92D and 92E , "international transaction" means a
transaction between two or more associated enterprises, either
international transaction.
92B.(1) For the purposes of this section and sections
92 , 92C , 92D and 92E , "international transaction" means a
transaction between ... Section 92 (1) which states that any income arising
from an international transaction shall be computed having regard to the
ALP, Section 92C (1) which
international transaction.
92B.(1) For the purposes of this section and sections
92 , 92C , 92D and 92E , "international transaction" means
a transaction between ... Section 92 (1) which states that any income
arising from an international transaction shall be computed having regard
to the ALP, Section 92C (1) which
address the issues, it would be relevant to refer
to Section 92C of the Act. The relevant extracts of which are set out
below ... computed by the
most appropriate method as is referred to in Section 92C(1) . Sub-rule (1)
of Rule 10C of the Rules postulates that
charged for such
services is chargeable to service tax under Section 66 read with Section
65(105)(zzzzu ... amended by, inter alia,
insertion of Article 268A as well as Entry 92C in List-I of the Seventh
Schedule to the Constitution of India
service tax with effect from 1st May 2011 in the form of Sections
65 (105) (zzzzv) and (zzzzw) was beyond its legislative competence. He
submitted ... List II (the State list). He pointed out that Entry 92C of List I
which provides „Taxes on Services‟ is yet to be notified
