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1,252 orders · Page 9 of 26
The High Court held that the impugned notice-cum-order was issued without providing the petitioner an opportunity of being heard. Therefore, the recovery under the notice could not be sustained.
The High Court held that appeals under Section 260-A are not maintainable unless there is an ex-facie perversity in the ITAT's findings. The court found that the issues raised, concerning the selection of comparables and filters, do not constitute substantial questions of law.
The High Court held that appeals under Section 260-A of the IT Act are not maintainable if they do not raise substantial questions of law. Disputes regarding the selection of comparables in transfer pricing do not typically constitute substantial questions of law.
The High Court held that appeals under Section 260-A of the IT Act are not maintainable if they merely question the selection of comparables or the application of filters, as these do not raise substantial questions of law.
The High Court held that the reopening of assessment under Section 147 was without jurisdiction as the AO had no tangible material to believe that income had escaped assessment. The court found that the AO had already applied their mind to the issue in the original assessment, and the reopening was based on an audit query and a change of opinion.
The High Court held that appeals under Section 260-A of the IT Act are not maintainable for issues concerning the selection of comparables or the application of filters, unless there is ex-facie perversity. Mere dissatisfaction with the Tribunal's findings of fact is insufficient.
The High Court held that appeals under Section 260-A of the IT Act are not maintainable for disputes regarding the selection of comparables unless there is ex-facie perversity. Mere dissatisfaction with factual findings of the Tribunal is insufficient.
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 ITAT's findings. Disputes regarding the selection of comparables do not constitute substantial questions 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. Issues regarding the selection of comparables or filters do not give rise to substantial questions of law.
The High Court held that appeals concerning the selection of comparables and filter applications in transfer pricing do not raise substantial questions of law. Such appeals are not maintainable under Section 260-A unless ex-facie perversity is established.
The High Court held that appeals concerning the selection of comparables and application of filters for transfer pricing do not raise substantial questions of law. 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 are not maintainable unless ex-facie perversity in the ITAT's findings is established. Disputes regarding the selection of comparables do not constitute substantial questions of law.
The High Court held that appeals under Section 260-A do not lie for disputes concerning the selection of comparables or the application of filters, unless there is ex-facie perversity. Therefore, no substantial question of law arose.
The High Court held that appeals under Section 260-A of the IT Act are not maintainable if there is no ex-facie perversity in the ITAT's findings. Disputes regarding the selection of comparables do not typically raise substantial questions of law.
The High Court directed the ITAT to consider the application for deferment on its merits. Until the deferment application is decided, the ITAT shall not proceed with the hearing of ITA No.478/BANG/2017.
The High Court directed the ITAT to first decide the application for deferment of hearing on its merits. Until the deferment application is decided, the ITAT is restrained from proceeding with the hearing of the appeal.
The Tribunal's order is upheld, finding that the Assessing Officer correctly determined the income by disallowing excess expenditure. The assessment was limited to 75% of the income chargeable under the State Act, and the Assessing Officer did not vary the computation made by the Central Officers.
The High Court directed the ITAT to first decide the application for deferment filed by the Revenue. Until the deferment application is decided on its merits, the ITAT shall not proceed with the hearing of the appeal.
The High Court held that appeals under Section 260-A of the Income Tax Act are not maintainable unless ex-facie perversity in the ITAT's findings is established. Issues regarding the selection of comparables or filters do not give rise to substantial questions of law.
The High Court found the trial court's acquittal to be perverse and erroneous, not based on proper appreciation of evidence and settled principles. It held that the presumption under Section 139 of the N.I. Act was not rebutted by the accused.
The High Court observed that the reassessment orders for the challenged period were confirmed by the Commissioner of Income Tax (Appeals). Therefore, the current writ petition was rendered infructuous.
The High Court held that appeals concerning the selection of comparable companies in transfer pricing cases do not raise substantial questions of law. Such appeals are not maintainable under Section 260-A of the Income Tax Act unless there is ex-facie perversity in the Tribunal's findings.
The High Court found that the Income Tax Officer had acted illegally and high-handedly by recovering an excessive amount of tax before the appeal period expired. The court ordered the refund of the excess amount recovered.
The High Court allowed the withdrawal of the appeal by the Revenue Department. This was based on a revised CBDT circular that increased the monetary limit for filing appeals before the High Court.
The High Court held that no substantial question of law arose from the ITAT's remand order. The court found that the ITAT was justified in remanding the case for a transfer pricing analysis using the combined transaction approach for royalty payments.
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 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 Income Tax Act are not maintainable unless ex-facie perversity in the ITAT's findings is established. Disputes regarding the selection of comparable companies do not raise substantial questions of law.
The High Court allowed the Revenue to withdraw the appeal based on the revised circular. The appeal was disposed of as withdrawn without answering the questions of law.
The High Court held that appeals concerning the selection of comparables for transfer pricing do not raise substantial questions of law 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 noted that the tax effect in the appeal 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 disputes regarding the selection of comparable companies in transfer pricing cases do not ordinarily give rise to substantial questions of law. Therefore, appeals challenging such findings are not maintainable under Section 260-A of the Income Tax Act.
The High Court noted that the tax effect in the present case was less than the revised monetary limit. The Revenue did not press the appeal and sought to withdraw it in terms of the circular.
The High Court held that appeals under Section 260-A of the Income Tax Act do not lie merely on dissatisfaction with the Tribunal's findings of fact regarding comparables. Such appeals are maintainable only if a substantial question of law arises.
The High Court held that appeals concerning the selection of comparables in transfer pricing cases do not raise substantial questions of law. Therefore, the appeal filed by the Revenue was dismissed.
The High Court noted that the tax effect in the present case was below the revised monetary limit for filing appeals. The Revenue did not press the appeal and sought to withdraw it based on the circular.
The High Court noted that the tax effect was below the prescribed limit for High Court appeals. Consequently, the Revenue did not press the appeal.
The High Court noted that the tax effect in the appeal was below the revised monetary limit set by the CBDT. Consequently, the Revenue did not press the appeal.
The tribunal was justified in holding the insurer of the car liable for the compensation. While the tribunal awarded 30% for future prospects, which could be reduced to 25% as per precedent, the absence of awards for loss of consortium and parental consortium offsets this. Therefore, the appeal and cross-objection are dismissed.
The High Court disposed of the appeal as withdrawn. The court noted that the Revenue did not press the appeal and sought to withdraw it in terms of the CBDT circular.
The High Court noted that the Revenue did not press the appeal due to the tax effect being below the prescribed monetary limit. Consequently, the appeal was dismissed as not pressed.
The High Court noted that the tax effect in the appeal was below the revised monetary limit for filing appeals before the High Court. Consequently, the Revenue did not press the appeal.
The High Court noted that the tax effect in the appeal was below the revised monetary limit for filing appeals. Consequently, the Revenue did not press the appeal.
The High Court held that appeals concerning the selection of comparables in transfer pricing cases do not raise substantial questions of law. Such appeals are not maintainable under Section 260-A of the Income Tax Act.
The High Court noted that the tax effect in the present case was below the revised monetary limit. Consequently, the Revenue did not press the appeal.
The High Court noted that the tax effect in the appeal was less than the revised monetary limit for filing appeals before the High Court. Consequently, the Revenue did not press the appeal.
The High Court noted that the tax effect in the appeal was less than the revised monetary limit for filing appeals before the High Court. Consequently, the Revenue did not press the appeal.
The High Court noted that the tax effect in the present case was below the revised monetary limit. The Revenue's counsel did not press the appeal and sought to withdraw it based on the circular.
The High Court held that appeals concerning the selection of comparables and application of filters do not raise substantial questions of law. The court followed its earlier judgment in a similar case, 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 do not lie for disputes concerning the selection of comparables unless there is ex-facie perversity. Mere dissatisfaction with the Tribunal's findings on facts is insufficient.
The High Court held that appeals under Section 260-A of the Income Tax Act are not maintainable if they merely question the selection of comparables or the application of filters, unless ex-facie perversity is established. Such issues do not give rise to substantial questions of law.