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6 results for “capital gains”+ Section 195clear

Sorted by relevance

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Key Topics

Section 26017Section 408Section 10A6Depreciation3Disallowance3Section 1952Section 260A2Section 102Deduction2

PR COMMISSIONER OF INCOME TAX-4 vs. M/S JEANS KNIT PVT LTD

In the result, we do not find any

ITA/580/2016HC Karnataka19 Oct 2020

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 10Section 260Section 260A

Section except in respect of capital gains and share premium amount is not a capital gain earned. It is urged that since, the tribunal has failed to determine the core issue with regard to colorable devise adopted by the 15 assessee, to evade tax, therefore, the matter be remitted to the tribunal for decision afresh in accordance with

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

Appeals are dismissed

ITA/11/2022HC Karnataka
07 Feb 2025

Bench: V KAMESWAR RAO,S RACHAIAH

Section 260

gains derived from the alienation of any such right or property which are contingent on the productivity, use, or disposition thereof ; and (b) payments of any kind received as consideration for the use of, or the right to use, any industrial, commercial, or scientific equipment, other than payments derived by an enterprise described in paragraph 1 of Article 8 (Shipping

PR. COMMISSIONER OF vs. M/S TALLY SOLUTIONS PVT LTD.,

In the result, the appeals fail and are hereby

ITA/199/2017HC Karnataka16 Dec 2020

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 195Section 260Section 40

195 of the Act on the aforesaid payment, therefore, disallowance under Section 40(a)(ia) of the Act has rightly been made. It is also argued that Section 40 of the Act begins with a non obstante clause and has an overriding effect on Sections 3 to 38 of the Act and therefore, in case, any deduction is claimed under

PR COMMISSIONER OF INCOME TAX-7 vs. M/S TALLY SOLUTIONS PVT LTD

In the result, the appeals fail and are hereby

ITA/951/2017HC Karnataka16 Dec 2020

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 195Section 260Section 40

195 of the Act on the aforesaid payment, therefore, disallowance under Section 40(a)(ia) of the Act has rightly been made. It is also argued that Section 40 of the Act begins with a non obstante clause and has an overriding effect on Sections 3 to 38 of the Act and therefore, in case, any deduction is claimed under

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

195 of the Act. 7. It is also argued that since payment to non resident was in the nature of royalty in terms of Explanation 2 to Section 9(1)(vi) of the Act and no TDS 16 was deducted on the payment, therefore, disallowance under Section 40(a)(ia) of the Act has rightly been made. It is also

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

The appeal stands dismissed

ITA/223/2018HC Karnataka12 Mar 2021

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

Section 143(3)Section 144Section 260Section 40Section 5(2)(b)Section 9(1)(i)Section 92C

capital importing countries, that is, developing nations. Here comes the principle of nexus, for the nexus of the right to tax is in the source rule. It is founded on the right of a country to tax the income earned from a source located in the said State, irrespective of the country of the residence of the recipient