9911796707
| TMI General Search |
|
Advanced Search Options
Showing 61 to 80 of 1750 Records Search Text: Ip support services india pvt ltd |
| Search Results |
| Articles (6) Case-Laws (1674) Circulars (30) News (28) Notifications (11) Schedules (1) |
|
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 functional profile, assets, risks and activities of the assessee company are admittedly similar to the previous assessment years. Following the earlier years orders in the assessee s own case and the order of the Tribunal in the case of Yahoo Software development India P. Ltd.[ 2022 (7) TMI 1349 - ITAT BANGAL... ... ...
2020 (3) TMI 1418 - ITAT MUMBAI TP Adjustment - ALP determination - ALP for the purchase of MSA[Masters Services Agreement] - from the associate concern as argued that neither the TPO nor the DRP has followed any of the transfer pricing method as specified in section 92C of the Act to determine the ALP for the purchase of MSA from the associate concern HELD THAT:- Section 92C(1) of the Act provides that the international transaction between the assessee and AE has to be on the basis of any of the method being the most appropri... ... ...
2025 (3) TMI 453 - ITAT HYDERABAD TP Adjustment - comparable selection - HELD THAT:- Tata Elxsi Limited owns significant intangible assets which contributes to its revenue. Assessee-company is a simple captive service provider to it s AE, whereas, Tata Elxsi Limited is a company which provides a software development services to multiple segments and to different verticals of industry. Therefore, the said company cannot be comparable to assessee-company. Persistent Systems Limited is engaged in diversified activities, whereas, th... ... ...
2024 (11) TMI 1002 - COMPETITION COMMISSION OF INDIA (LB) Seeking confidentiality over its identity under provisions of Section 57 of the Act read with Regulation 35 of the Competition Commission of India (General) Regulations, 2009 - bid-rigging and cartelisation - abuse of dominant position - contravention of Section 3 of the Competition Act, 2002 - HELD THAT:- There was a significant difference of more than INR 2000/- between bids quoted by OP-2 and OP-3; in the remaining two tenders viz. Tender Nos. 03221028 and 03211577, there seems to be a minor ... ... ...
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 Ltd.UK to be in the nature of royalty - HELD THAT:- The assessee does not get any right to use the copyright in the software as it merely has access to the information / data processed by the software / application which is owned and executed by Symbiotics Ltd. UK in its server located in UK. What the... ... ...
2023 (9) TMI 973 - ITAT BANGALORE TP Adjustment - comparable selection - HELD THAT:- Arvind Lifestyle Brands Limited - We remand this comparable back to the Ld.AO/TPO to carry out necessary verification having regard to the annual reports of this comparable that has already there placed on record. Assessee may assist the Ld.TPO/AO in determining the eligibility of this comparable by providing relevant information as called for. Needless to say that proper opportunity of being heard must be granted to assessee. Exclusion of KD Tr... ... ...
2023 (9) TMI 204 - ITAT MUMBAI TP Adjustment - ALP of the international transaction of purchase of equity shares - Transaction of purchase of shares of SIPL and QNPL by the Appellant from its AE - Grievance of the Appellant is that the Final Assessment Order passed by the Assessing Officer is silent on the proposed downward adjustment in relation to the cost of acquisition of shares in the subsequent years - HELD THAT:- We find merit in the contention advanced by the Appellant that the TPO could not have substituted the actua... ... ...
2023 (1) TMI 1323 - SECURITIES APPELLATE TRIBUNAL, MUMBAI Prohibition of manipulative, fraudulent and unfair trade practices - charge that NSE and its employees have colluded with TMs, especially OPG Securities Pvt. Ltd. - profit made by ISB in its report is on the basis of early login by OPG - show cause notice alleged that OPG gained materially by being the first logger as well as by connecting to the secondary server -WTM directed OPG debarring accessing the securities market for a period of five years and restraining OPG from taking any new clients... ... ...
2022 (12) TMI 1062 - NATIONAL COMPANY LAW APPELLATE TRIBUNAL , PRINCIPAL BENCH , NEW DELHI Conspiracy - omission and commission of misconduct by official of Pune Municipal Corporation in connivance with appellants filed a detailed information application before the CCI - levy of penalty - HELD THAT:- On examination of entire material we are of the opinion that sufficient evidence were brought on record to show forming cartelisation by the appellants in influencing tender. It was specific case of contravention of Section 3(3)(d) of the Act read with Section 3(1) of the Act. Besides evi... ... ...
2022 (11) TMI 1395 - Supreme Court Termination of Power Purchase Agreement (PPA), which was entered into by the Appellant and the first Respondent - statutory contract or not - scope of judicial review of action by the State in a matter arising from a contract - concept of public law in judicial review in a contractual matter - arbitration Clause in regard to the subject matter - case of the first Respondent is on par with Renew Energy or not - non-compliance of Article 9.1 of the PPA, namely, the effect of Appellant not issuing ... ... ...
2023 (6) TMI 907 - AUTHORITY FOR ADVANCE RULINGS CUSTOMS, MUMBAI Classification of goods proposed to be imported - 15 models of Data Center Switch Routers belonging to 3 different series - classifiable under the Tariff Item 8517 62 90 of the Customs Tariff of India or not - applicability of Sr. No. 13N of Notification No. 24/2005-Customs dated 01.03.2005 and Sr. No. 20 of Notification No. 50/2017-Customs, dated 30.06.2017. HELD THAT:- Sub-heading 851762 covers machines for the reception, conversion and transmission or regeneration of voice, images or other da... ... ...
2022 (10) TMI 1039 - ITAT BANGALORE Royalty payment - payments made by the Appellate under the Distribution Agreement - characterisation of the payments to Google Ireland - scope of Section 9(1)(vi) of the Income-tax Act, 1961 and Article 12 of the Double Taxation Avoidance Agreement between India and Ireland - assessee (Google India Private Limited) (GIPL) is a company engaged in the business of providing Information Technology (IT) and Information Technology Enabled Services (ITES) to its group companies. The definition of the t... ... ...
2020 (5) TMI 160 - ITAT BANGALORE Disallowance of depreciation on the WDV of imported software - assessee had claimed depreciationon the WDV of imported software - assessee did not deduct tax at source on the payment made for purchase of software, the AO took the view that depreciation claimed by the assessee is not allowable as deduction u/s 40(a)(ia) - HELD THAT:- We are concerned here with AY 2012-13 and during the year under consideration, the assessee has claimed only depreciation thereon. In the earlier years, the AO had o... ... ...
2019 (12) TMI 1280 - ITAT COCHIN TP Adjustment - consideration of SEZ Unit setting up expenses and Ireland branch expenses as operating in nature while computing the margin of the assessee and consideration of unrealized foreign exchange gain/loss while computing the margin of the assessee - HELD THAT:- The issue with regard to foreign fluctuation expenses, the Chennai Bench in the case of Infac India Pvt. Ltd. vs. DCIT [ 2018 (10) TMI 1814 - ITAT CHENNAI] , we direct the Assessing Officer to exclude the loss on account of fore... ... ...
2019 (5) TMI 1249 - CESTAT NEW DELHI Commercial Training or Coaching Service or not - consideration received from the students towards the conduct of a test known as International English Language Testing System (IELTS) - HELD THAT:- A perusal the relevant clauses of the agreement clearly show that the agreement is with regard to the holding of the IECTS Test by the Appellant. There is nothing in the agreement which may require the Appellant to coach or train any candidate desires of appearing at the IELTS Test nor any consideratio... ... ...
Effective rates of customs duty and IGST for goods imported into India. Here is a concise summary of the notification:The notification details the effective rates of customs duty and Integrated Goods and Services Tax (IGST) for various goods imported into India as of 30th June 2017. It provides a comprehensive table specifying:1. Chapter or heading of goods2. Description of goods3. Standard customs duty rate4. Integrated GST rate5. Applicable conditionsKey features:- Issued under the Customs Act, 1962 and Customs Tariff Act, 1975- Supersedes previous notification No. 12/2012-Customs- Covers a wide range of goods from animals and agricultural products to industrial machinery and electronics- Provides exemptions or reduced duty rates for specific categories of imports- Includes conditions for availing concessional rates- Aims to facilitate trade, support specific industries, and provide relief for certain importsThe notification is extensive, covering hundreds of items across multiple chapters and providing detailed specifications for customs duty and tax treatment.
2017 (4) TMI 37 - CESTAT NEW DELHI Export of services - Refund claim - unutilised CENVAT credit - denial on the ground that the services provided by the appellant appear to fall under the category of ‘intellectual property service’ and not under ‘engineering consultancy service’ as claimed by the appellant and also on the ground that the services were rendered in India and cannot be categorized as export. Held that: - the services rendered by the appellant will fall under the category of taxable services provided or to be provide... ... ...
2016 (10) TMI 1394 - ITAT BANGALORE TP Adjustment - comparable selection - Applicability of turnover filter - TPO has applied turnover slab of Rs.1 crore to Rs.200 crores for excluding some of the companies - HELD THAT:- As it gives ambiguous result as two entities having difference of Rs.1 crore cannot be considered as comparable, whereas on the other hand difference of Rs.199 crores can be considered as comparable company. Therefore, such classification of comparables on the basis of Rs.1 Crore to Rs.200 Crores of turnover is no... ... ...
2015 (10) TMI 2431 - ITAT DELHI Transfer pricing adjustment - selection of comparables - Held that:- CAT Technologies Ltd has earned Medical transcription receipts of Rs. 83.74 lac and Training income of Rs. 2.44 lac, both of which have been combined with the income from Software development and consulting services. One cannot ascertain with precision the contribution made by the income from Medical transcription and Training to the overall profitability of CAT Technologies Ltd., so that the other income may be segregated. As ... ... ...
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'ble Apex Court in the case of Anjum H Ghaswala [2001 (10) TMI 4 - SUPREME Court]. In this view of the matter, we uphold the action of the Assessing Officer in charging the assessee the said interest. The Assessing Officer is, however, directed to recompute the interest chargeable under Sections 234... ... ...
|
