ITO v. PKS

152 DTR 215Reported decision2017#8207 most cited

What is ITO v. PKS authority for?

Transactions are genuine and bonafide, not sham, and the real income concept should be followed.

13

judgments rely on this decision, according to BharatTax’s citation analysis of 366,315 Indian tax judgments — from 2020 to 2020.

Also referred to as

ITO v. PKS · 152 DTR 215 · genuine transactions · bonafide transactions · sham transactions · real income concept · CIT(A) observation

Judgments citing ITO v. PKS

M/S. Vijayalaxmicashew Co., Kollam vs. The ACIT, Kollam

In the result, the appeals of the assessees in ITA Nos

ITA 49/COCH/2016[2011-12]Status: DisposedITAT Cochin03 Feb 2020AY 2011-12

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

…. (2018) 404 ITR 409 wherein it was held that transactions are genuine &bonafide& not sham. Real income concept to be followed which CIT(A) had rightly observed. The Ld. AR relied on the decisions of the Tribunal in the case of ITO vs. PKS Holdings (2017) 152 DTR 215 (Kol) (Trib.) and in the case of Flipkart India (P) Ltd. vs. ACIT (2018) 193 TTJ (Bang.) 685. The Ld. AR relied on the judgment of the Supreme Court in the case of CIT & ANR vs. Glaxo Smithkline Asia (P) Ltd. (2010) 236 CTR (SC) 113 (2018) 168 DTR (Mumbai) (Trib.) 161 wherein it was held that exercise of addition alleging underpricing is reven…

M/S. Vijayalaxmicashew Co., Kollam vs. The ACIT, Kollam

In the result, the appeals of the assessees in ITA Nos

ITA 48/COCH/2016[2010-11]Status: DisposedITAT Cochin03 Feb 2020AY 2010-11

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

…. (2018) 404 ITR 409 wherein it was held that transactions are genuine &bonafide& not sham. Real income concept to be followed which CIT(A) had rightly observed. The Ld. AR relied on the decisions of the Tribunal in the case of ITO vs. PKS Holdings (2017) 152 DTR 215 (Kol) (Trib.) and in the case of Flipkart India (P) Ltd. vs. ACIT (2018) 193 TTJ (Bang.) 685. The Ld. AR relied on the judgment of the Supreme Court in the case of CIT & ANR vs. Glaxo Smithkline Asia (P) Ltd. (2010) 236 CTR (SC) 113 (2018) 168 DTR (Mumbai) (Trib.) 161 wherein it was held that exercise of addition alleging underpricing is reven…

M/S. Vijayalaxmicashew Co., Kollam vs. The ACIT, Kollam

In the result, the appeals of the assessees in ITA Nos

ITA 47/COCH/2016[2008-09]Status: DisposedITAT Cochin03 Feb 2020AY 2008-09

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

…. (2018) 404 ITR 409 wherein it was held that transactions are genuine &bonafide& not sham. Real income concept to be followed which CIT(A) had rightly observed. The Ld. AR relied on the decisions of the Tribunal in the case of ITO vs. PKS Holdings (2017) 152 DTR 215 (Kol) (Trib.) and in the case of Flipkart India (P) Ltd. vs. ACIT (2018) 193 TTJ (Bang.) 685. The Ld. AR relied on the judgment of the Supreme Court in the case of CIT & ANR vs. Glaxo Smithkline Asia (P) Ltd. (2010) 236 CTR (SC) 113 (2018) 168 DTR (Mumbai) (Trib.) 161 wherein it was held that exercise of addition alleging underpricing is reven…

Sri.K.Ravindranathan Nair, Kollam vs. The ACIT, Kollam

In the result, the appeals of the assessees in ITA Nos

ITA 46/COCH/2016[2008-09]Status: DisposedITAT Cochin03 Feb 2020AY 2008-09

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

…. (2018) 404 ITR 409 wherein it was held that transactions are genuine &bonafide& not sham. Real income concept to be followed which CIT(A) had rightly observed. The Ld. AR relied on the decisions of the Tribunal in the case of ITO vs. PKS Holdings (2017) 152 DTR 215 (Kol) (Trib.) and in the case of Flipkart India (P) Ltd. vs. ACIT (2018) 193 TTJ (Bang.) 685. The Ld. AR relied on the judgment of the Supreme Court in the case of CIT & ANR vs. Glaxo Smithkline Asia (P) Ltd. (2010) 236 CTR (SC) 113 (2018) 168 DTR (Mumbai) (Trib.) 161 wherein it was held that exercise of addition alleging underpricing is reven…

Smt. T.C. Usha, Kollam vs. The ACIT, Kollam

In the result, the appeals of the assessees in ITA Nos

ITA 45/COCH/2016[2010-11]Status: DisposedITAT Cochin03 Feb 2020AY 2010-11

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

…. (2018) 404 ITR 409 wherein it was held that transactions are genuine &bonafide& not sham. Real income concept to be followed which CIT(A) had rightly observed. The Ld. AR relied on the decisions of the Tribunal in the case of ITO vs. PKS Holdings (2017) 152 DTR 215 (Kol) (Trib.) and in the case of Flipkart India (P) Ltd. vs. ACIT (2018) 193 TTJ (Bang.) 685. The Ld. AR relied on the judgment of the Supreme Court in the case of CIT & ANR vs. Glaxo Smithkline Asia (P) Ltd. (2010) 236 CTR (SC) 113 (2018) 168 DTR (Mumbai) (Trib.) 161 wherein it was held that exercise of addition alleging underpricing is reven…

Smt. T.C. Usha, Kollam vs. The ACIT, Kollam

In the result, the appeals of the assessees in ITA Nos

ITA 44/COCH/2016[2009-10]Status: DisposedITAT Cochin03 Feb 2020AY 2009-10

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

…. (2018) 404 ITR 409 wherein it was held that transactions are genuine &bonafide& not sham. Real income concept to be followed which CIT(A) had rightly observed. The Ld. AR relied on the decisions of the Tribunal in the case of ITO vs. PKS Holdings (2017) 152 DTR 215 (Kol) (Trib.) and in the case of Flipkart India (P) Ltd. vs. ACIT (2018) 193 TTJ (Bang.) 685. The Ld. AR relied on the judgment of the Supreme Court in the case of CIT & ANR vs. Glaxo Smithkline Asia (P) Ltd. (2010) 236 CTR (SC) 113 (2018) 168 DTR (Mumbai) (Trib.) 161 wherein it was held that exercise of addition alleging underpricing is reven…

Sri.R.Prakash, Kollam vs. The ACIT, Kollam

In the result, the appeals of the assessees in ITA Nos

ITA 43/COCH/2016[2011-12]Status: DisposedITAT Cochin03 Feb 2020AY 2011-12

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

…. (2018) 404 ITR 409 wherein it was held that transactions are genuine &bonafide& not sham. Real income concept to be followed which CIT(A) had rightly observed. The Ld. AR relied on the decisions of the Tribunal in the case of ITO vs. PKS Holdings (2017) 152 DTR 215 (Kol) (Trib.) and in the case of Flipkart India (P) Ltd. vs. ACIT (2018) 193 TTJ (Bang.) 685. The Ld. AR relied on the judgment of the Supreme Court in the case of CIT & ANR vs. Glaxo Smithkline Asia (P) Ltd. (2010) 236 CTR (SC) 113 (2018) 168 DTR (Mumbai) (Trib.) 161 wherein it was held that exercise of addition alleging underpricing is reven…

Sri.R.Prakash, Kollam vs. The ACIT, Kollam

In the result, the appeals of the assessees in ITA Nos

ITA 42/COCH/2016[2010-11]Status: DisposedITAT Cochin03 Feb 2020AY 2010-11

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

…. (2018) 404 ITR 409 wherein it was held that transactions are genuine &bonafide& not sham. Real income concept to be followed which CIT(A) had rightly observed. The Ld. AR relied on the decisions of the Tribunal in the case of ITO vs. PKS Holdings (2017) 152 DTR 215 (Kol) (Trib.) and in the case of Flipkart India (P) Ltd. vs. ACIT (2018) 193 TTJ (Bang.) 685. The Ld. AR relied on the judgment of the Supreme Court in the case of CIT & ANR vs. Glaxo Smithkline Asia (P) Ltd. (2010) 236 CTR (SC) 113 (2018) 168 DTR (Mumbai) (Trib.) 161 wherein it was held that exercise of addition alleging underpricing is reven…

Sri.R.Prakash, Kollam vs. The ACIT, Kollam

In the result, the appeals of the assessees in ITA Nos

ITA 41/COCH/2016[2009-10]Status: DisposedITAT Cochin03 Feb 2020AY 2009-10

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

…. (2018) 404 ITR 409 wherein it was held that transactions are genuine &bonafide& not sham. Real income concept to be followed which CIT(A) had rightly observed. The Ld. AR relied on the decisions of the Tribunal in the case of ITO vs. PKS Holdings (2017) 152 DTR 215 (Kol) (Trib.) and in the case of Flipkart India (P) Ltd. vs. ACIT (2018) 193 TTJ (Bang.) 685. The Ld. AR relied on the judgment of the Supreme Court in the case of CIT & ANR vs. Glaxo Smithkline Asia (P) Ltd. (2010) 236 CTR (SC) 113 (2018) 168 DTR (Mumbai) (Trib.) 161 wherein it was held that exercise of addition alleging underpricing is reven…

Sri.R.Prakash, Kollam vs. The ACIT, Kollam

In the result, the appeals of the assessees in ITA Nos

ITA 40/COCH/2016[2010-11]Status: DisposedITAT Cochin03 Feb 2020AY 2010-11

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

…. (2018) 404 ITR 409 wherein it was held that transactions are genuine &bonafide& not sham. Real income concept to be followed which CIT(A) had rightly observed. The Ld. AR relied on the decisions of the Tribunal in the case of ITO vs. PKS Holdings (2017) 152 DTR 215 (Kol) (Trib.) and in the case of Flipkart India (P) Ltd. vs. ACIT (2018) 193 TTJ (Bang.) 685. The Ld. AR relied on the judgment of the Supreme Court in the case of CIT & ANR vs. Glaxo Smithkline Asia (P) Ltd. (2010) 236 CTR (SC) 113 (2018) 168 DTR (Mumbai) (Trib.) 161 wherein it was held that exercise of addition alleging underpricing is reven…

Sri.R. Pratap, Kollam vs. The ACIT, Kollam

In the result, the appeals of the assessees in ITA Nos

ITA 39/COCH/2016[2010-11]Status: DisposedITAT Cochin03 Feb 2020AY 2010-11

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

…. (2018) 404 ITR 409 wherein it was held that transactions are genuine &bonafide& not sham. Real income concept to be followed which CIT(A) had rightly observed. The Ld. AR relied on the decisions of the Tribunal in the case of ITO vs. PKS Holdings (2017) 152 DTR 215 (Kol) (Trib.) and in the case of Flipkart India (P) Ltd. vs. ACIT (2018) 193 TTJ (Bang.) 685. The Ld. AR relied on the judgment of the Supreme Court in the case of CIT & ANR vs. Glaxo Smithkline Asia (P) Ltd. (2010) 236 CTR (SC) 113 (2018) 168 DTR (Mumbai) (Trib.) 161 wherein it was held that exercise of addition alleging underpricing is reven…

Sri.R. Pratap, Kollam vs. The ACIT, Kollam

In the result, the appeals of the assessees in ITA Nos

ITA 38/COCH/2016[2010-11]Status: DisposedITAT Cochin03 Feb 2020AY 2010-11

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

…. (2018) 404 ITR 409 wherein it was held that transactions are genuine &bonafide& not sham. Real income concept to be followed which CIT(A) had rightly observed. The Ld. AR relied on the decisions of the Tribunal in the case of ITO vs. PKS Holdings (2017) 152 DTR 215 (Kol) (Trib.) and in the case of Flipkart India (P) Ltd. vs. ACIT (2018) 193 TTJ (Bang.) 685. The Ld. AR relied on the judgment of the Supreme Court in the case of CIT & ANR vs. Glaxo Smithkline Asia (P) Ltd. (2010) 236 CTR (SC) 113 (2018) 168 DTR (Mumbai) (Trib.) 161 wherein it was held that exercise of addition alleging underpricing is reven…

Sri.R. Pratap, Kollam vs. The ACIT, Kollam

In the result, the appeals of the assessees in ITA Nos

ITA 37/COCH/2016[2009-10]Status: DisposedITAT Cochin03 Feb 2020AY 2009-10

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

…. (2018) 404 ITR 409 wherein it was held that transactions are genuine &bonafide& not sham. Real income concept to be followed which CIT(A) had rightly observed. The Ld. AR relied on the decisions of the Tribunal in the case of ITO vs. PKS Holdings (2017) 152 DTR 215 (Kol) (Trib.) and in the case of Flipkart India (P) Ltd. vs. ACIT (2018) 193 TTJ (Bang.) 685. The Ld. AR relied on the judgment of the Supreme Court in the case of CIT & ANR vs. Glaxo Smithkline Asia (P) Ltd. (2010) 236 CTR (SC) 113 (2018) 168 DTR (Mumbai) (Trib.) 161 wherein it was held that exercise of addition alleging underpricing is reven…