| Title |
Citation |
Court |
Gist |
Download |
Commissioner of Income Tax - 10 vs. M/s CA
Computer Associates India Private Limited |
ITA No.20 of 2011 Asst. Year 2002-2003 |
Bombay High Court |
Bad-debts cannot be the relevant factor to determine the arm’s length price of the royalty transaction between the licensee and the licensor. |
|
| M/s. Bayer Material Science P. Ltd. Vs. ACIT |
ITA No.7977/Mum/2010 : Asst. Year 2006-2007 |
Mumbai Tribunal |
The Mumbai Tribunal held that in absence of valid comparable uncontrolled data,
comparable controlled data can be used for the purpose of benchmarking the
international transaction of the appellant with its associated enterprise. |
|
M/s. Delmas, France Vs. The Addl. Director of
Income-tax |
ITA No.9001/Mum/10 : Asst. Year 2006-2007 |
Mumbai Tribunal |
The Mumbai Tribunal held that as long as it is not shown that the transaction
between the agent and the principal are not made under the arm’s length condition, the
agent is treated as an independent agent under the India France DTAA |
|
