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2023 (5) TMI 1209 - ITAT HYDERABAD
Depreciation on goodwill - goodwill as acquired during business acquisition - Company has entered into a business acquisition agreement to acquire the business of four Soft Limited ('Four Soft&... ...
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2021 (2) TMI 575 - ITAT DELHI
TP Adjustment - Comparable selection - functional dissimilarity - HELD THAT:- Assessee is into rendering Information Technology Enabled Services (ITES) related to IP administration/renewal and data m... ...
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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... ...
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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 A... ...
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2016 (3) TMI 510 - CESTAT CHENNAI
Valuation - Related party transaction value - inclusion of royalty - whether royalty paid is for condition of sale or not - Legality of Commissioner (Appeals) order - Held that:- the Lower Appellate A... ...
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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 matte... ...
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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. ... ...
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2022 (7) TMI 1391 - ITAT BANGALORE
TP Adjustment - comparable selection - Turnover and Abnormal Profits Filter - exclusion of Celestial Biolabs Ltd. raised - HELD THAT:- We are of the opinion that, this comparable cannot be compared w... ...
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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 inte... ...
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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 prov... ...
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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... ...
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2019 (8) TMI 1394 - ITAT DELHI
TP Adjustment - operating margin - market support services - comparable selection - HELD THAT:- cost of marketing team should be bifurcated based on revenue of AE from its operations in India vis a... ...
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2019 (2) TMI 2022 - ITAT DELHI
TP Adjustment - adjustment to the value of international transactions pertaining to provision of software development services by the Appellant under Section 92CA(3) - Comparable selection - PERSISTE... ...
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2019 (1) TMI 522 - NATIONAL COMPANY LAW TRIBUNAL, CHANDIGARH
Initiation of Corporate Insolvency Resolution Process under section 10 of Insolvency & Bankruptcy Code 2016 - sub rule (1) of Rule 7 of Insolvency and Bankruptcy (Application to Adjudicating Authority... ...
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2018 (11) TMI 338 - NATIONAL COMPANY LAW TRIBUNAL, CHANDIGARH
Corporate insolvency proceedings - claim of operational debt - Held that:- Section 3(6) (a) would not be applicable since the applicant has not proved that he has a right to payment. We have noted abo... ...
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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 clear... ...
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2016 (12) TMI 1655 - ITAT DELHI
TPA - comparable selection criteria - Held that:- Assessee being global leader in manufacture, integration and support of IP based, end-to-end networking and telecommunication solutions, set up its br... ...
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2015 (10) TMI 2431 - ITAT DELHI
Transfer pricing adjustment - selection of comparables - Held that:- CAT Technologies Ltd has earned Medical transcription receipts of ₹ 83.74 lac and Training income of ₹ 2.44 lac, both o... ...
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2015 (9) TMI 1630 - ITAT BANGALORE
Adjustment in the arm’s length price(ALP) of international transaction entered into by the Assessee with it’s Associated Enterprise (AE) u/s 92 - Assessee provided Software Development Services to its... ...
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2014 (11) TMI 551 - ITAT DELHI
Transfer pricing adjustment – Selection of comparables - Accel Transmatic Limited (Software Services segment) - Determination of ALP on international transaction - Design and development support servi... ...