M/s Tally Solutions Private Limited Vs. Deputy Commissioner of Income Tax, Bangalore for ITA No. 1235(Bang)/2010; AY- 2006- 07 Facts:– The taxpayer was engaged in the business of software development, marketing and sale of ‘tally’ branded financial accounting and management software. On 31 January, 2006 it sold its intellectual property rights including patent, copyrights and […]
Li & Fung (India) Pvt. Ltd. Vs. DCIT (ITAT Delhi)- ITA No. 5156/Del/2010] Tribunal ruling that the amount of compensation to be received ought to be a reflection of the functions performed, assets deployed and risks assumed by the associated enterprises (‘AE’) whilst discharging the business. On the concept of location savings the Tribunal held […]
Abhiram Seth Vs. JCIT (ITAT Delhi) Facts :- Abhiram Seth (the assessee) was employed in an executive position with M/s. PepsiCo India Holdings (P) Ltd., part of PepsiCo Inc.The assessee was granted valuable rights in shares of Pepsi Co Inc. Employees’ Stock Options [ESOP] held with Barry Group of Merrill Lynch [Trust], USA. Such rights […]
