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2018 (2) TMI 1783 - ITAT DELHI
Depreciation on computer peripherals, assessee claimed depreciation on the equipment like UPS, stabilizer, LAN/WAN, catalyst switches, network switches etc. at 60% - Held that:- We find that the equip... ...
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2017 (10) TMI 1090 - ITAT BANGALORE
Google Adword program functions and work - Royalty payment - Use of Intellectual Property through ITES agreement - amount payable by the Appellant to Google Ireland for the subject assessment years - ... ...
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2015 (10) TMI 485 - ITAT BANGALORE
Interest under Section 234D - Held that:- The charging of interest is consequential and mandatory and the Assessing Officer has no discretion in the matter. This proposition has been upheld by the Hon... ...
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2023 (6) TMI 607 - ITAT BANGALORE
TP Adjustment - Comparable selection - Larsen and Toubro Infotech Ltd., (ii) Mindtree Limited, (iii) Persistent Systems Ltd., and (iv) Infosys Limited - HELD THAT:- In the present case, the functiona... ...
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2017 (12) TMI 1117 - ITAT KOLKATA
TPA - comparable selection criteria - Held that:- Assessee is engaged in cutting edge product without appreciating that the products are not conceptualized in India and hence the role of PSC is limite... ...
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2022 (12) TMI 1412 - ITAT BANGALORE
TP adjustment - Exclusion of subcontracting charges - determination of net cost margin excluding the sub-contract charges is decided against the assessee by coordinate bench of this Tribunal in as... ...
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2023 (1) TMI 1066 - ITAT BANGALORE
TP Adjustment - comparable Selection - assessee has challenged that the upper turnover of the companies selected by the TPO which are more than 200.00/- crores cannot be considered as a good comparab... ...
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2022 (7) TMI 489 - ITAT BANGALORE
TPA - Comparable selection - Functional dissimilarity - HELD THAT:- Infosys Ltd.company earns income from both rendering software services and development of products. Despite rendering diverse servi... ...
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2018 (6) TMI 618 - AUTHORITY FOR ADVANCE RULINGS, NEW DELHI
Fixed place PE of the Applicant in India - Taxability of fees in respect of the services rendered for use of a global network and infrastructure to process card payment transactions for customers in I... ...
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2023 (4) TMI 1263 - ITAT INDORE
TP Adjustment - additional ground before the DRP rejecting economic analysis undertaken by the assessee, most specifically that of depreciation adjustment - AR submitted that the assessee before the ... ...
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2020 (11) TMI 1079 - ITAT BANGALORE
TP Adjustment - comparable selection - HELD THAT:- Companies functionally dissimilar with that of assessee engaged in Software Development Services and provides maintenance of service to ARM Limited,... ...
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2019 (12) TMI 1279 - ITAT BANGALORE
TP Adjustment - comparable selection - functional dissimilarity - HELD THAT:- Assessee is engaged in the business of software development and related services to its Associated Enterprises (AEs), SSI... ...
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2019 (9) TMI 1664 - ITAT BANGALORE
TP Adjustment - comparable Companies selection - HELD THAT:- In facts of present case, assessee is doing part of software development cycle and therefore has been categorised as a captive software de... ...
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2018 (10) TMI 583 - ITAT KOLKATA
TPA - ALP adjustment - methods prescribed under the Act for determination of the ALP of these inter-group services - determination of ALP of the international transaction of payments made under CCA, a... ...
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2018 (9) TMI 2129 - COMPETITION COMMISSION OF INDIA NEW DELHI
Anti-competitive agreements - Joint tender floated by Public Sector Oil Marketing Companies (PSU OMCs/OMCs) on 02.01.2013 for procurement of anhydrous alcohol - quoting an exorbitant price for supply ... ...
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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... ...
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2007 (7) TMI 684 - DELHI HIGH COURT
MR. Sanjay Kishan Kaul, J. For Appellant/Petitioner/plaintiff: Prathiba M. Singh and Bishwajit Dubey, Advs For Respondents/Defendant: P.V. Kapur, Sr. Adv. and Sumeet Mehra and Thomas George,... ...
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2024 (5) TMI 1209 - APPELLATE AUTHORITY FOR ADVANCE RULING, HARYANA
Non-Payment of Required Fee for Filing an Appeal - Appeal against the order of AAR - Classification of services - licensing services received by the applicant from SIBV, under the MLA and the TLA - Wh... ...
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2023 (11) TMI 390 - ITAT DELHI
TDS u/s 195 - disallowances u/s 40(i)(a) - payments made to Dubai Leading Technologies - whether India-UAE DTAA has no clause on Fee for Technical Services? - HELD THAT:- We do not find any infirmity ... ...
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2023 (9) TMI 978 - ITAT DELHI
TDS u/s 195 - disallowance u/s 40(a)(i) on account of alleged non-deduction of tax at source by the assessee while making remittance to Symbiotics Ltd., UK - AO held the payments made to Symbiotics Lt... ...
