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Showing 101 to 120 of 1750 Records Search Text: Ip support services india pvt ltd |
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2021 (3) TMI 803 - ITAT PUNE TP Adjustment - foreign exchange fluctuation gain/loss should be treated as non operating income/expenses for the purpose of computation of Profit Level Indicator (PLI) of the tested party and the comparables - HELD THAT:- Tribunal in the case of Ameriprise India (P) Ltd. [ 2016 (3) TMI 1272 - DELHI HIGH COURT] this issue is answered in favour of the assessee and the TPO/AO is directed to determine the ALP of the international transactions afresh after considering forex gain/loss as operating in... ... ...
2020 (5) TMI 662 - ITAT DELHI Transfer pricing adjustment to the international transaction of provision of software development services - Comparable selection - HELD THAT:- Assessee is into developing software for the associated enterprises thus companies functionally dissimilar with that of assessee need to be deselected from final list.... ... ...
2020 (5) TMI 7 - NATIONAL COMPANY LAW TRIBUNAL, KOLKATA Maintainability of application - initiation of CIRP - Corporate Debtor failed to make repayment of its debt - existence of debt and dispute or not - time limitation - acknowledgement of debt - HELD THAT:- The amount of debt and default is not in dispute. Time Limitation - HELD THAT:- It is not in dispute that such amount of debt due and payable by the Corporate Debtor to the Financial Creditor has is appearing in the financial statements for the year ended 31-3-2018. It is also not in dispute th... ... ...
2018 (11) TMI 1744 - ITAT KOLKATA TP Adjustment - interest rate charged by the appellant on the loans granted to AE - LIBOR (US) rate application - HELD THAT:- The assessee had indeed charged its associates enterprises the interest in question @ 6%. The lower authorities had made the impugned adjustment by computing ALP thereupon @ 8.73%. The assessee had adopted Comparable Uncontrolled Price (CUP) method for its above benchmark. The CIT DR fails to dispute the clinching fact that the impugned adjustment is well within the toler... ... ...
2018 (6) TMI 37 - AUTHORITY FOR ADVANCE RULINGS-NEW DELHI TDS liability u/s 195 - Income accrued in India - fees for technical services - whether payments made on account of resell agreement are fees for technical services or royalty under India-US Treaty - DTAA - human intervention in providing technical services - withholding of tax - Held that:- On the issue of human intervention in providing technical services, we agree with the principle held in Bharti Cellular Limited [2008 (10) TMI 321 - DELHI HIGH COURT] as also upheld by the Apex Court [2010 (... ... ...
2017 (2) TMI 557 - ITAT DELHI Disallowance u/s 14A - Held that:- AO has failed to find out as to how the balance expenditure of Rs. 60.77 lacs claimed by assessee was incorrect or had any nexus with earning of exempt income. The AO also did not examine the stand of the assessee that administrative expenses of Rs. 10,70,000/- were in respect of a thin strength of employees who were working for providing IT enabled BPO Services and were not involved in the activity of making investment in shares or mutual funds. We also find s... ... ...
2014 (11) TMI 927 - CALCUTTA HIGH COURT Challenge to the Show Cause Notice - Business support service or not - security services provided by Assam Tea Plantation Security Force (ATPSF) to protect the planters and their property. - sovereign function or not - Held that:- The value of sovereign functions of a state is not taxable in the hands of the citizens. Support services rendered by the government are taxable. According to the government this kind of service received by the writ petitioner is classifiable as a “support service”. Th... ... ...
2013 (8) TMI 594 - ITAT DELHI Transfer pricing adjustment on account of royalty for brand name Rs. 981,406,624/- - Assessee in this case is a license manufacturer of cars in India of its Associated Enterprise SMC - In terms of the license assessee has paid lumpsum royalty as well as running royalty SMC. TPO was of the opinion that the royalty paid should be split towards technical assistance and brand – TPO concluded Suzuki brand was weak/worthless – Held that:- TPO has imputed a very large T.P. adjustment in respect of AMP ... ... ...
2025 (3) TMI 1458 - ITAT DELHI The appeal was partly allowed by the HC. The Court directed the exclusion of Tata Elxsi Ltd., Infosys Ltd., and Wipro Ltd. from the list of comparables, aligning with the appellant's functional profile. The issue of notional interest on delayed receivables was remanded to the TPO for reassessment, considering industry norms and mutual agreements. The Court reinforced that comparables must be functionally similar and that high-value companies with significant intangibles are unsuitable for comparison with routine service providers.
2025 (2) TMI 1031 - ITAT DELHI TP Adjustment - transaction of payment of royalty in relation to licensed manufacturing segment of the Appellant on various models - ALP benchmarking of Royalty Payment to non-UK entities - HELD THAT:- Facts and circumstances of the case required the learned TPO to be more objective in his approach to counter the compensation of 4 to 5% accepted in the case of assessee in the MAP proceedings for A.Y. 2013-14 or APA for A.Y. 2018-19 to 2022-23 and the treatment in A.Y. 201-11, 2011-12 and 2012-13... ... ...
2024 (7) TMI 1340 - DELHI HIGH COURT Taxability of receipts in India - Income deemed to accrue or arise in India - receipts from Indian customers for services provided outside the territory of India - whether taxable u/s 9 (1) (vi) of the Income Tax Act, 1961 read along with Article 12 of the DTAA between India and Singapore - According to the appellants, the receipts become taxable under the Act since the services provided are liable to be viewed as being in connection with the use or right to use of process or equipment - Scope o... ... ...
2024 (6) TMI 1284 - ITAT BANGALORE TP Adjustment - Non-grant of working capital adjustment - HELD THAT:- As relying on M/S. SOFTWARE AG BANGALORE [ 2016 (3) TMI 1384 - ITAT BANGALORE] and M/S. TIVO TECH PRIVATE LIMITED [ 2020 (6) TMI 708 - ITAT BANGALORE] negative working capital adjustment cannot be carried out, where the assessee was a captive service provider. Here also it is an admitted position that assessee was a captive service provider and its services are entirely rendered to its AE abroad. Its share capital was entirely... ... ...
2024 (5) TMI 908 - ITAT INDORE TDS u/s 194J/195 - whether payment of roaming charges falls within the meaning of FTS - assessee-in-default for non-deduction of tax at source out of payment of roaming charges - whether the payment of roaming charges constitutes FTS or Royalty? - Whether payment of roaming charges does not amount to royalty u/s 9(1)(vi) red with Explanation 6? - HELD THAT:- After a careful consideration, we find that it is vehemently held in various decisions, that such payment of roaming charges is neither in ... ... ...
2023 (2) TMI 903 - ITAT MUMBAI TP adjustment in respect of franchise fee - prudence of expenditure - TPO at threshold has discarded payment of franchise fee on the ground of need of such payment - HELD THAT:- TPO has exceeded his jurisdiction in making such observation. TPO cannot step into the shoes of assessee to decide prudence of expenditure. The TPO failed to examine the documents furnished by assessee to benchmark the transaction by applying one of the methods specified in Chapter-X of the Act. Thus, in the facts of the... ... ...
2022 (12) TMI 998 - ITAT Hyderabad TP adjustment - comparable selection - functional Dissimilarity - HELD THAT:- When an extra ordinary event takes place by way of amalgamation, then that company cannot be considered as a comparable. Companies functionally dissimilar with that of assessee and with huge turnover need to be deselected from final list. Interest on outstanding receivables - as submitted DRP had bench marked the international transaction by taking the Short Term deposit rate of SBI - HELD THAT:- DRP had restricted the... ... ...
2022 (6) TMI 1357 - ITAT BANGALORE TP adjustments - determination of Net Cost Margin - Determining effective NCP margin for provision of the software development services - TPO was of the view that the sub-contracting charges formed part of the operating cost of the Assessee for provision of SWD services and thus cannot be excluded from either its cost base or operating revenues as it would not give a correct picture of the profit margin earned by it - HELD THAT:- Determination of net cost margin excluding the sub-contract charge... ... ...
2021 (10) TMI 1094 - ITAT DELHI Loss incidental to business - non-recovery of certain business advances made to certain parties in the normal course of its business - Whether such loss incidental to business, upon being written off in the Books of the Appellant is a claimable deduction allowable u/s 28 r.w.s. 37 of the Income Tax Act, 1961? - AO and the CIT(A) held that the deduction claimed on account of advances written off was a claimable deduction only u/s 36(l)(vii) r.w.s.36(2) - HELD THAT:- Even though assessee might hav... ... ...
2021 (4) TMI 159 - ITAT HYDERABAD Admission of additional ground - Education cess - allowable deduction u/s. 37(1) - HELD THAT:- Apex court s landmark decision in National Thermal Power Co. Ltd. [ 1996 (12) TMI 7 - SUPREME COURT] as considered the All Cargo Global Logistics Ltd., [ 2012 (7) TMI 222 - ITAT MUMBAI(SB)] holds that this tribunal can very well entertain such legal ground so as to determine correct tax liability of an assessee subject to the condition that all the relevant facts form part of the records. We make it cl... ... ...
2021 (2) TMI 568 - Supreme Court Seeking Petitioners to undertake a comprehensive and heightened judicial scrutiny regarding the permissibility of the Central Vista Project of the Government of India - challenge is premised on high principles of democratic values as applicable in India and not limited to mere infringement of statutory provisions of the governing enactments - nature of project-being of high political significance and eminence for our democratic republic; and for upholding the Rule of Law , which is on a higher p... ... ...
2020 (6) TMI 584 - ITAT BANGALORE TP Adjustment - international transaction of provision of software development services [SWD services] to the assessee s Associated Enterprises [AE] - Comparable selection - HELD THAT:- Assessee provided software research development services and marketing technical support services to its AEs, thus companies functionally dissimilar with that of assessee need to be deselected, thus companies functional dissimilar with that of assessee need to be deselected from final list. Non-grant of working c... ... ...
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