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Showing 81 to 100 of 1750 Records Search Text: Ip support services india pvt ltd |
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2015 (8) TMI 263 - ITAT DELHI Transfer pricing adjustment - selection of comparable - Infosys BPO Ltd. Held that:- The assessee is a captive unit providing back office support services to its AE alone, which are basically in the nature of processing of insurance claims and the data entry, it can have no valid comparison with Infosys Ltd., as the latter is a full-fledged risk taking entrepreneur with diversified business including software product, consulting application, design development, re-engineering and maintenance etc... ... ...
2014 (8) TMI 591 - CESTAT MUMBAI Franchisee service - registration of website domain names - Reverse charge mechanism - whether the appellants are a franchisee service provider - Held that:- demand notices have been issued under the Franchise Service. The terms "Franchisee" and "Franchiser" have been defined under Section 65 (47) and 65 (48) of the Finance Act, 1994 - It would thus be seen from the definitions that franchisee means an agreement by which the franchisee is granted representational rights to sell or manufacture go... ... ...
2012 (2) TMI 172 - ITAT BANGALORE Transfer pricing - What is the data to be considered by the TPO at the time of determining ALP - Whether the appellant should have been given an opportunity to refute the material sought to be utilized by the TPO – Turnover filter – deduction u/s 10A - Held that:-By providing a specified date in the Act, the obligation is cast upon the assessee to keep and maintain the documents for that period. But, it does not restrict the TPO from making enquiries thereafter for determining the correct ALP. T... ... ...
2009 (3) TMI 868 - COMMISSIONER OF CUSTOMS AND CENTRAL EXCISE (APPEALS), KANPUR The appellate authority set aside the adjudicating authority's classification of the goods under Chapter 30, reclassifying them under Chapter Sub-Headings 56012110 and 52030000. The appellants were directed to determine any duty liability in consultation with the Range Officer. The penalty under Section 11AC was also set aside due to the absence of intent to evade duty.
2024 (7) TMI 287 - DELHI HIGH COURT Income deemed to accrue or arise in India - FTS - Geographical shift of IPL matches from India to South Africa and UAE - receipts as be attributable to a Permanent Establishment [PE] in India - whether business income was divisible under the DTAA even though it arose out of a single contract having regard to Articles 7 and 13 of the Convention? - services provided by IMG to BCCI under the Service Agreement qualify as fee for technical services in terms of Article 13 (4) (c) of the DTAA between I... ... ...
2023 (5) TMI 344 - Supreme Court Rejection of Resolution Plan - while rejecting matter remanded to the committee of creditors with directions to the resolution professional to proceed from the stage of publication of Form G , and invite the expression of interest afresh as per the Insolvency and Bankruptcy Board of India (Insolvency Resolution Process for Corporate Persons) Regulations, 2016 - ineligibility in terms of Section 88 of the Indian Trusts Act, 1882. Valuation: Regulations 27 and 35 - HELD THAT:- It is at once clear ... ... ...
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 DRP by way of an additional ground claimed adjustment on account of depreciation vis- -vis comparable companies - assessee sought adjustment because of the difference in the rates of depreciation charged by the assessee vis- vis the comparable companies - HELD THAT:- It is pertinent to note that the ... ... ...
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 assessee s own case for the AY 2011-12 [ 2016 (9) TMI 1458 - ITAT BANGALORE] . Comparable selection - directions to the AO/TPO to apply 15% RPT filter - We direct exclusion of Larsen Tubro Ltd., Persistant systems Ltd., RS Software (India) Ltd., and Infosys Ltd., from the final list. Interest on receivabl... ... ...
2020 (10) TMI 24 - ITAT DELHI TP Adjustment - comparable selection - Functional similarity - HELD THAT:- The assessee is engaged in the business of software development, maintenance and IT enabled services.It provides system integration, enterprise solutions, software development services to the clients of its associated enterprise and two other independent customer is in UK, US and other countries in Europe as well as in India. It provides information technology enabled services in the nature of back-office process outsourc... ... ...
2020 (1) TMI 460 - ITAT DELHI Revision u/s 263 - reassessment u/s 147 - AO was satisfied the explanation of the assessee with regard to Accommodation entries. - Assessee submitted that, assessment was reopened based on mere Investigation Wing appraisal report - Revenue submitted that, assessment erroneous as well as prejudicial to the interests of the Revenue because A.O. has not examined the seized material found during the course of search. Held that:- it is clear that the Addl. CIT and Ld. Pr. CIT while granting approval ... ... ...
2019 (9) TMI 609 - ITAT PUNE Subvention/ subsidy money receipt from its parent company Nalco, USA - revenue receipt exigible to tax or not? - Assessing Officer / TPO, pursuant to directions of DRP treated the said subvention amount received from its associated enterprises as non-operating income - HELD THAT:- The issue vis- -vis its taxability i.e. receipt of subvention from parent company now stands settled by recent decision of Hon ble Supreme Court in Siemens Public Communication Network (P.) Ltd. Vs. CIT [ 2016 (12) TMI... ... ...
2018 (12) TMI 1563 - ITAT DELHI TPA - Comparable selection - functinal dissimilarity - admission of the additional ground - Held that:- The Ld. CIT(DR) did not object to admission of the additional ground of appeal in view of the Assessee’s contention that relevant facts for adjudication of the additional ground of appeal are already on record of assessment proceedings. - the additional ground of appeal admitted. EIL cannot be taken as a suitable comparable company in the absence of its segmental accounts. As regards, comparab... ... ...
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 of ethanol to OMCs - contravention of the provisions of Section 3 of Competition Commission Act, 2002 - levy of monetary penalty. Whether the joint tender floated by OMCs is in violation of provisions of Section 3(1) read with Section 3(3) of the Act? - HELD THAT:- The Commission holds that floating... ... ...
2018 (6) TMI 1688 - ITAT BANGALORE TP Adjustment - Comparable selection - negative working capital adjustment - HELD THAT:- Basis of the working capital adjustment is the existence of a difference in the cost of working capital and it is also stated that this is relevant because the cost is stated to affect the margin and in the assessee s case, the assessee has demonstrated that it holds its working capital at no cost, completely out of its own funds without any borrowings at all. In our considered opinion, these factors are not... ... ...
2017 (3) TMI 1933 - ITAT BANGALORE Computation of deduction u/s 10A - HELD THAT:- We find that this issue is covered by the Jurisdictional High Court s decision in CIT v Tata Elxsi [ 2011 (8) TMI 782 - KARNATAKA HIGH COURT] . It clearly lays down the principle that while computing deduction u/s 10A, if the export turnover is calculated after excluding certain expenses, such expenses should also be excluded in computing the total turnover. Since the DRP s decision is in accordance with the ratio of the jurisdictional High Court, s... ... ...
2025 (5) TMI 274 - ITAT BANGALORE ITAT Case Summary:The SC/ITAT ruled in favor of the assessee, rejecting revenue's claims regarding tax withholding on payments to a USA-based subsidiary and non-resident individual. The tribunal determined that technical services did not constitute "making available" technical knowledge, and sales commissions were professional services not subject to Indian taxation. Payments were deemed to have a source outside India, and provisions without actual credit did not trigger tax deduction obligations. The revenue's appeal was dismissed, and the total demand was deleted.
2024 (10) TMI 980 - CESTAT NEW DELHI Levy of service tax - Intellectual Property Right Services - income received from the transfer of goodwill - Whether goodwill is covered in the definition of IPR Service as per the Finance Act and that is this same as trademark as has been held by Original Authority? - Manpower Recruitment or Supply Agency Service - extended period of limitation - penalty - HELD THAT:- The donor, a legal practitioner has institutionalized the Goodwill of his profession/business associated with the name of his bu... ... ...
2022 (7) TMI 1365 - ITAT DELHI Income deemed to accrue or arise in India - Royalty receipts - Receipts from distribution/supply of software - attribution to profit when the transaction has been found to at Arm s Length between foreign party and the Indian AE - amount received by ADIR from sale of software to Indian distributors as royalty income u/s 9(1)(vi) as well as under Article 12(3) of India Ireland tax treaty and taxed the same at the rates applicable with receipt as royalty income - Whether assessee was having fixed p... ... ...
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 services, there are no segmental details in respect of the services rendered. The company provides end-to-end business solutions like business consulting, technology, engineering and outsourcing services. In addition, the company offers software products and platforms for banking industry. The company als... ... ...
2021 (10) TMI 1391 - ITAT DELHI TP Adjustment - comparable selection - inclusion of E-clerx Services Ltd and TCS E-Serve Ltd. - HELD THAT:- This Tribunal has excluded E-clerx Services Ltd and TCS E-Serve Ltd. from the final set of comparables. Respectfully following the decision of this Tribunal in own case [ 2021 (2) TMI 575 - ITAT DELHI] , we direct the Assessing Officer/TPO to exclude E-clerx Services Ltd and TCS E-Serve Ltd. from the final set of comparables. Ground with its sub grounds is, accordingly, allowed. Addition o... ... ...
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