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1,252 orders · Page 18 of 26
The High Court held that appeals under Section 260-A of the Income Tax Act do not lie for disputes concerning the selection of comparables or filters used in transfer pricing, unless there is ex-facie perversity. Mere dissatisfaction with the Tribunal's findings of fact is insufficient to invoke Section 260-A.
The High Court held that the Tribunal was correct in granting exemption under Section 11. It also upheld the Tribunal's decision to disallow additions made by the assessing authority concerning building and infrastructure development funds.
The High Court held that the issue regarding the exclusion of expenses from turnover is covered by the Supreme Court's decision in HCL Technologies Ltd. Furthermore, the court found that appeals concerning the selection of comparables do not give rise to substantial questions of law.
The High Court held that appeals under Section 260A of the Income Tax Act are not maintainable if they merely question the selection of comparables or the application of filters, unless there is an ex-facie perversity in the ITAT's findings. Such issues do not give rise to substantial questions of law.
The tribunal held that the lease did not automatically renew and that the lessee's claim for an extended lease based on oral assurances was not valid. The court found that the tenancy was validly terminated by the purchaser.
The Tribunal held that if a transaction is accepted as at arm's length for one party, it should also be considered at arm's length for the other party. It also noted that the TPO/AO had not properly considered the assessee's reasons for incurring a loss. However, the High Court found no substantial question of law.
The High Court held that appeals under Section 260-A are not maintainable if they do not raise substantial questions of law. Mere dissatisfaction with the Tribunal's findings of fact is insufficient.
The High Court noted the submission of the University that they would consider the representation within a reasonable time. Consequently, the Court directed the University to consider the representation and pass necessary orders within eight weeks.
The High Court disposed of the appeal as withdrawn. This was based on the revised monetary limits for filing appeals by the Revenue, as per the CBDT circular.
The High Court held that while the ITAT cannot condone delays beyond six months under Section 254(2), the High Court, exercising its writ jurisdiction, can condone the delay in exceptional circumstances to do substantial justice. The Court found that the petitioner had made out a case for interference.
The High Court held that appeals under Section 260-A of the Income Tax Act are not maintainable if they merely challenge the Tribunal's findings on facts, such as the selection of comparables, unless the findings are ex facie perverse. The Court found no substantial question of law arising from the ITAT's order.
The High Court held that appeals under Section 260-A of the Income Tax Act are not maintainable if they do not raise substantial questions of law. Mere dissatisfaction with the Tribunal's findings of fact is insufficient.
The High Court noted that the tax effect in the present case was below the revised monetary limit for filing appeals before the High Court. Consequently, the Revenue did not press the appeal.
The High Court held that the issue of internet charges was covered by the Supreme Court's decision in HCL Technologies Ltd. Regarding transfer pricing comparables and foreign exchange fluctuations, the court found that such issues do not give rise to substantial questions of law under Section 260-A.
The High Court held that no substantial question of law arises in the appeal. It relied on Supreme Court and its own previous judgments, stating that disputes over comparable selection do not typically warrant an appeal under Section 260-A.
The High Court allowed the Revenue to withdraw the appeal based on a CBDT circular revising monetary limits for appeals. The appeal was disposed of as withdrawn without answering the substantial questions of law.
The High Court held that appeals under Section 260-A are maintainable only if they raise substantial questions of law. Appeals concerning the selection of comparables in transfer pricing do not typically raise such substantial questions.
The High Court held that the appeals filed by the Revenue did not raise substantial questions of law. The court relied on Supreme Court and its own previous judgments regarding the non-maintainability of appeals on factual findings of the Tribunal.
The High Court held that appeals under Section 260-A are maintainable only if they raise substantial questions of law. Appeals concerning the selection of comparables or factual findings of the Tribunal do not generally give rise to such questions.
The High Court held that appeals under Section 260-A of the Income Tax Act are not maintainable if they merely question factual findings of the Tribunal regarding comparables and filters, unless the findings are ex facie perverse. The Court found no substantial question of law in this case.
The High Court held that appeals under Section 260-A are not maintainable if they do not raise substantial questions of law. Mere dissatisfaction with the Tribunal's findings on facts, such as the selection of comparables, does not constitute a substantial question of law.
The High Court held that appeals under Section 260-A of the IT Act are not maintainable unless ex-facie perversity in the ITAT's findings is established. Disputes regarding the selection of comparables or adjustments do not typically raise substantial questions of law.
The High Court held that appeals concerning the selection of comparables or the application of filters for arriving at a correct list of comparables do not give rise to substantial questions of law. Therefore, the appeal filed by the Revenue was dismissed.
The High Court noted that the learned counsel appearing for the appellants – Revenue, Mr. K.V. Aravind, wanted to withdraw the appeal as it had become infructuous. Accordingly, the Court dismissed the present appeal as withdrawn. No decision was made on the merits of the case. The operative direction was to send a copy of the appeal to the Respondent – Assessee forthwith. No issues were expressly left undecided as the appeal was withdrawn.
The High Court held that appeals concerning the selection of comparables and adjustments in transfer pricing do not raise substantial questions of law. Therefore, the appeal filed by the Revenue was dismissed.
The High Court held that communication expenses deducted from export turnover must also be deducted from total turnover, citing Supreme Court precedent. For other transfer pricing issues, the Tribunal had remanded the matter to the AO for reconsideration in light of its guidelines.
The High Court held that appeals under Section 260-A are not maintainable if they merely question the Tribunal's findings on facts, such as the selection of comparables. Mere dissatisfaction with factual findings is insufficient to raise a substantial question of law.
The High Court held that expenses reduced from export turnover must also be reduced from total turnover, citing Supreme Court precedent. The Court also found that the appeals did not raise substantial questions of law, particularly regarding the selection of comparables.
The High Court held that no substantial question of law arose from the ITAT's order. The court relied on its previous judgments and Supreme Court decisions, stating that mere dissatisfaction with factual findings of the Tribunal is insufficient to invoke Section 260-A.
The High Court found no substantial question of law arose for consideration in the appeal. It disposed of the appeal, leaving the question open for future determination.
The High Court held that appeals under Section 260A of the Income Tax Act are not maintainable unless an ex-facie perversity in the ITAT's findings is established. Dissatisfaction with factual findings is insufficient.
The High Court held that no substantial question of law arises for consideration in the appeal. The court dismissed the appeal, upholding the ITAT's decision that the assessee was eligible for the benefit of the erstwhile proviso to Section 92C(2).
The High Court held that appeals under Section 260-A of the Income Tax Act are not maintainable if they do not raise substantial questions of law. Mere dissatisfaction with the Tribunal's findings of fact is insufficient.
The High Court held that no substantial question of law arises in the appeal. It relied on its previous judgment stating that appeals concerning the selection of comparables or filters for arriving at the ALP do not present substantial questions of law.
The High Court held that the issue regarding the deduction of telecommunication charges was covered by previous judgments, including a Supreme Court decision. For the second issue, the court referred to its own precedent stating that appeals under Section 260-A are not maintainable if they do not raise substantial questions of law, particularly concerning factual findings like the selection of comparables.
The High Court held that appeals under Section 260-A of the IT Act are not maintainable unless ex-facie perversity in the ITAT's findings is established. Disputes regarding the selection of comparable companies do not typically raise substantial questions of law.
The High Court held that appeals under Section 260-A are not maintainable if they merely question factual findings of the Tribunal regarding comparables or methods. The court found no substantial question of law arose in this case.
The High Court held that the appeal did not raise any substantial questions of law. It relied on previous judgments stating that mere dissatisfaction with the Tribunal's findings of fact is insufficient to invoke Section 260-A.
The High Court held that appeals under Section 260-A of the IT Act are not maintainable unless there is an ex-facie perversity in the Tribunal's findings. Mere dissatisfaction with factual findings does not raise a substantial question of law.
The High Court held that appeals under Section 260-A are not maintainable if they do not raise substantial questions of law. Issues regarding the selection of comparables and filters do not, in their considered opinion, give rise to such questions.
The Tribunal modified the operating profit adjustment factor to 20% and deleted the disallowance under Section 10A, directing consequential benefits. The High Court found no substantial question of law and dismissed the appeal.
The High Court held that the respondent societies were not co-operative banks as they did not meet the cumulative conditions stipulated in the Banking Regulation Act. Therefore, they continued to be treated as co-operative societies eligible for exemption under Section 80P(2)(a)(i).
The High Court held that the respondent societies were not co-operative banks as they did not meet the cumulative conditions stipulated in the Banking Regulation Act. Therefore, they continued to be treated as co-operative societies eligible for exemption under Section 80P(2)(a)(i).
The High Court held that the respondent societies were not co-operative banks as they did not meet the cumulative conditions stipulated in the Banking Regulation Act. Therefore, they continued to be treated as co-operative societies eligible for exemption under Section 80P(2)(a)(i).
The High Court held that the respondent societies were not co-operative banks as they did not meet the cumulative conditions stipulated in the Banking Regulation Act. Therefore, they continued to be treated as co-operative societies eligible for exemption under Section 80P(2)(a)(i).
The High Court held that the complainant's claim of lending Rs. 2,04,000 in cash without any documentation, especially as the wife of a Railway Constable, was unnatural and doubtful. The court found that the accused had effectively rebutted the presumption under Section 139 of the NI Act through cross-examination of the complainant.
The High Court held that appeals under Section 260-A of the IT Act are not maintainable unless ex-facie perversity in the ITAT's findings is established. Issues regarding the selection of comparables and filters do not give rise to substantial questions of law.
The High Court held that telecommunication charges and expenses incurred abroad should be reduced from both export and total turnover for Section 10A deduction, citing Supreme Court precedent. It also found that the appeal did not raise any substantial question of law.
The High Court held that appeals under Section 260-A of the Income Tax Act are not maintainable unless the Tribunal's finding is ex facie perverse. Mere dissatisfaction with findings of fact is insufficient to invoke Section 260-A.
The High Court held that appeals under Section 260-A are not maintainable unless ex-facie perversity in the Tribunal's findings is established. Dissatisfaction with factual findings is insufficient to raise a substantial question of law.