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

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

Transfer Pricing Officer for determination of arms’ length price. As per the return filed the tax payable was Rs.48,38,27,302/-. The assessee also claimed TDS

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

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

Transfer Pricing Officer for determination of arms’ length price. As per the return filed the tax payable was Rs.48,38,27,302/-. The assessee also claimed TDS

PR COMMISSIONER OF vs. M/S WIPRO LIMITED

In the result, the appeal is disposed of in terms

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Transfer Pricing Officer (TPO) to follow the directions given by the tribunal in earlier Assessment Year. The tribunal with regard to claim of assessee under Section 14A of the Act directed the Assessing Officer to follow the directions given the claim of the assessee under Section 14A of the Act set aside the finding recorded by the Assessing Officer

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

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

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

Transfer Pricing Officer had chosen comparables after satisfying required tests namely, qualitative and quantitative filers and considering their functions and as such the order passed by Tribunal is perverse in nature? 2. Whether on the facts and in the circumstances of the case, the Tribunal’s order can be said as perverse in nature as Tribunal has directed the assessing

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

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

Transfer Pricing Officer?" 4. "Whether on the facts and in the circumstances of the case, the Tribunal is right in allowing working capital adjustment without an upper limit would result into abnormal adjustment and would make the profit earned within the permitted range even when if no operating profit is earned and the upper limit of working capital adjustment should

M/S SUBEX LTD vs. THE DEPUTY COMMISSIONER

Appeal is allowed

Bench: P.S.DINESH KUMAR,UMESH M ADIGA

Transfer Pricing Officer 4 Dispute Resolution Panel I.T.A No.787/2017 4 the ITAT. The ITAT upheld the relief granted by DRP except the year-end provisions made towards legal and professional charges. In this appeal, we are concerned with the disallowance of the provision for legal and professional charges. 4. Shri. K.K. Chaithanya, learned Senior Advocate for the assessee submitted that

PR. COMMISSIONER OF INCOME TAX-5 vs. M/S. PUMA SPORTS INDIA P., LTD.,

The appeal stands dismissed

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

transfer pricing adjustment for Rs.4,16,65,106/- on the basis of the order passed under Section 92CA of the Act dated 24.10.2016. The assessing authority also made other additions. The assessee’s objections were not considered by the Dispute Resumption Panel and therefore, an appeal was 3 filed before the Income Tax Appellate Tribunal, Bangalore (hereinafter referred

ASSISTANT COMMISSIONER OF INCOME TAX vs. M/S GULBARGA ELECTRICITY SUPPLY COMPANY LTD.

Accordingly, appeal of Revenue is dismissed

Bench: B.VEERAPPA,VINEET KOTHARI

price fixed by KERC. Assessee was oblivious to the technical expertise which the KPTCL may possess. There was neither transfer of any technology nor any service attributable to a technical service offered by the KPTCL and accepted by the assessee. Therefore, application of Section 194J of the Act to the facts of this case by the Revenue is misconceived.” (emphasis

THE COMMISSIONER OF INCOME TAX vs. HUBLI ELECTRIC SUPPLY COMPANY LTD

In the result, these appeals fail and accordingly stand

Bench: S.ABDUL NAZEER,P.S.DINESH KUMAR

TDS)2 has dismissed the appeals by the impugned order. Thus, he submitted that the instant appeals do not merit any consideration and accordingly prayed for their dismissal. 7. We have given our careful considerations to the submission made by the learned counsel for the Revenue and the assessee. Revenue is aggrieved by the decision of the ITAT holding that

BENEFIT FILM CITY (INDIA) LTD vs. SHRI GOPAL S PANDIT

Bench: The Hon'Ble Mr.Justice B.V.Pinto

transferred from the plaintiff to defendants through cheques and that the said cheques have been duly acknowledged by 5 the defendants and all those payments were prior to the Sale Deeds and hence he submits that the plaintiff is entitled for an equitable order of injunction restraining the defendants from alienating the suit schedule properties to any other parties than

L. VENKATARAMANA RAJU vs. UNION OF INDIA

Bench: The Hon'Ble Mr.Justice S.R.Krishna Kumar

Price Advisory Committee which has been approved by the Board in its 356th meeting held on 20.09.2018, that the compensation shall be awarded at Rs.50 Lakhs per acre on consent and if the land owners are not agreeable for such consent awards, the award shall be made in accordance with law. The Board has filed objections to the said application

M/S SRI BALAJI CORPORATE SERVICES vs. UNION OF INDIA MINISTRY OF FINANCE

Bench: The Hon'Ble Mr.Justice S.R.Krishna Kumar

Price Advisory Committee which has been approved by the Board in its 356th meeting held on 20.09.2018, that the compensation shall be awarded at Rs.50 Lakhs per acre on consent and if the land owners are not agreeable for such consent awards, the award shall be made in accordance with law. The Board has filed objections to the said application

THE COMMISSIONER OF INCOME TAX vs. M/S MANIPAL HEALTH SYSTEMS PVT LTD

Appeals are partly allowed to the extent indicated

Bench: S.SUJATHA,VINEET SARAN

transferring patients to their own clinics or any other hospital. This condition imposed by the assessee-company would not alter the nature of professional service rendered by the doctors. Tribunal also held that none of the doctors are entitled to gratuity, PF, LTA and other terminal benefits. Considering all these aspects at length a detailed, well reasoned order is passed

THE COMMISSIONER OF INCOME TAX vs. M/S MANIPAL HEALTH SYSTEMS

Appeals are partly allowed to the extent indicated

Bench: S.SUJATHA,VINEET SARAN

transferring patients to their own clinics or any other hospital. This condition imposed by the assessee-company would not alter the nature of professional service rendered by the doctors. Tribunal also held that none of the doctors are entitled to gratuity, PF, LTA and other terminal benefits. Considering all these aspects at length a detailed, well reasoned order is passed

THE COMMISSIONER OF INCOME TAX vs. M/S URBAN LADDER HOME DECOR SOLUTIONS PVT LTD

Appeals are dismissed

Bench: V KAMESWAR RAO,S RACHAIAH

TDS by relying on the decision of the Supreme Court in the case of Engineering Analysis (supra) is clearly distinguishable on facts. In support of his submissions, he has heavily relied upon the assessment order and the order in appeal before the CIT(A). 8. On the other hand, Sri. Sandeep Huilgol, learned counsel appearing for the respondent-assessee

THE PR COMMISSIONER OF INCOME TAX vs. SHRI H NAGARAJA

Bench: S SUNIL DUTT YADAV,B.S PATIL

TDS deductions were placed before the Assessing Officer for scrutiny and based on the said details, the Assessing Officer was satisfied and had dropped further proceedings, and therefore, the Revisional Commissioner was not right and justified in insisting for profiting details for service as the same was not permissible in law. Reliance is placed on the judgment of the Apex