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Section 26017 Section 10A6 TDS3 Disallowance3 Section 402 Section 1952 Deduction2 Transfer Pricing2 Comparables/TP2

PR COMMISSIONER OF vs. M/S WIPRO LIMITED

In the result, the appeal is disposed of in terms

ITA/464/2017HC Karnataka09 Dec 2020

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 10ASection 260Section 260ASection 32

TDS on payment made to purchase of software and has claimed depreciation under Section 32 of the Act on such software. It is also pointed out that the intent of disallowance under Section 40(a)(ia) of the Act is to ensure prevention of revenue leakage on foreign payments as recovery of tax from non resident payees was difficult. With

M/S. CHARIOT INTERNATIONAL (P) LTD vs. DY.COMMISSIONER OF INCOME TAX

In the result, the appeal fails and is hereby

ITA/230/2014HC Karnataka19 Nov 2020

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 10BSection 143(1)Section 195Section 260

10B of the Act. The return was processed under Section 143(1) of the Act and was subsequently taken up for scrutiny. During the course of the assessment, the assessee was called upon the explain as to why the gross sales commission paid to 4 the foreign parties / non-residents to the extent of Rs.39,94,627/- without deduction

PR. COMMISISONER OF INCOME TAX - 3, vs. M/S INFINEON TECHNOLOGIES INDIA PVT. LTD.,

The appeal is disposed of with liberty as prayed for by the learned

ITA/478/2023HC Karnataka25 Sept 2024

Bench: S.G.PANDIT,C.M. POONACHA

Section 201Section 260Section 40

10b, which are exhaustive and if so, whether it is legally permissible to bypass the same partially or by implication"? 2. "Whether on the facts and circumstances of the case and in law, the Tribunal is right in law in excluding M/s.L & T Infotech Ltd, M/s.Persistent - 4 - NC: 2024:KHC:39905-DB ITA No. 478 of 2023 Systems Ltd, M/s.CG

THE PR COMMISSIONER OF INCOME TAX vs. ADC INDIA COMMUNICATIONS LTD

The appeal is disposed of with liberty as prayed for by the learned

ITA/494/2022HC Karnataka30 Sept 2024

Bench: S.G.PANDIT,C.M. POONACHA

Section 260Section 40Section 40A(7)Section 9(1)(vii)

10B of the Rules and by applying RPM method as most appropriate method? 4. Whether on the facts and in the circumstances of the case, The Tribunal is right in law in directing the assessing authority to exclude comparable in list even when the TPO has chosen proper comparable by application of all required tests

M/S WIPRO LIMITED vs. THE DEPUTY COMMISSIONER OF INCOME TAX

The appeals stand disposed of, accordingly

ITA/881/2008HC Karnataka25 Mar 2015

Bench: N.KUMAR,B.SREENIVASE GOWDA

Section 260

Section 145A of the Income- tax Act which was inserted with effect from assessment year 1999-2000. The said provision states that the valuation of stock should include the amount of any tax duty, cess or fee - 94 - actually paid or incurred to bring the goods to its present location and condition. The Department has followed a consistent stand

THE COMMISSIONER OF INCOME TAX vs. M/S WIPRO LTD

The appeals stand disposed of, accordingly

ITA/211/2009HC Karnataka25 Mar 2015

Bench: N.KUMAR,B.SREENIVASE GOWDA

Section 260