Supreme Court · 2007 INSC 735 · Decided 9 July 2007
M/S. Dit (International Taxation), Mumbai v. M/S. Morgan Stanley & CO.
- Court
- Supreme Court of India
- Citation
- 2007 INSC 735 · [2007] 8 S.C.R. 52
- Case number
- CIVIL APPEAL No. 2914/2007
- Decided
- 9 July 2007
- Bench
- ARIJIT PASAYAT, S.H. KAPADIA (2-judge bench)
- Outcome
- Case Partly allowed
- Case type
- Civil
- Acts & sections cited
- Income Tax Act
Headnote
Income Tax Act, 1961: c Section 92-lnterniitional transaction-Computation of income from- Arm's length price-Relevance of-Methods to determine-Authority for Advanced Ruling (AAR)-Permanant Establishment (PE)-Projits attributable to-Morgan Stanley & Co. (MSC) has three main lines of business, and credit services- MSCO had set up a captive Business Process Out sourcing (BPO) in India, D namely, Morgan Stanley Advantage Services (MSAS)-MSCo accordingly made an application seeking an Advance Ruling as to whether it was having \. a permanent Establishment (PE) in India and, if so, the
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