The Tax Publishers2020 TaxPub(DT) 4626 (SC)

INCOME TAX ACT, 1961

Section 261 Section 92C

Where the Department preferred SLP to appeal against the judgment of Bombay High Court in Pr. CIT v. Concentrix Services (I) (P) Ltd. [ITA Nos. 778, 867 of 2017, dt. 4-9-2019] : (2019) 267 Taxman 625 (Bom) : 2019 TaxPub(DT) 7274 (Bom-HC), whereby the High Court held that acquisition of business by way of investing into shares of that company through either Special Purpose Vehicle or directly could not be considered to be ordinary event of the business and therefore, could not be termed as expenditure incurred for the purpose of assessee's business, which was providing ITES services, the Supreme Court dismissed the SLPs on the ground of delay.

Appeal (Supreme Court) - Special leave petition - Transfer pricing - Determination of ALP--Issuance of corporate guarantee

Department preferred SLP to appeal against the judgment of Bombay High Court in Pr. CIT v. Concentrix Services (I) (P) Ltd. [ITA Nos. 778, 867 of 2017, dt. 4-9-2019] : (2019) 267 Taxman 625 (Bom) : 2019 TaxPub(DT) 7274 (Bom-HC), whereby the High Court held that acquisition of business by way of investing into shares of that company through either Special Purpose Vehicle or directly could not be considered to be ordinary event of the business and therefore, could not be termed as expenditure incurred for the purpose of assessee's business, which was providing ITES services, the Supreme Court dismissed the SLPs on the ground of delay. Held: The Supreme Court dismissed the SLPs on the ground of delay.

REFERRED :

FAVOUR : SLP dismissed.

A.Y. :



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