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5 results for “condonation of delay”+ Transfer Pricingclear

Sorted by relevance

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Key Topics

Section 2607Section 194J3Section 92C3Transfer Pricing3Section 143(3)2Section 194C2Section 260A2Section 92B2Section 10A2

PR. COMMISSIONER OF INCOME TAX-2 vs. TOYOTA TSUSHO INDIA PRIVATE LIMITED

ITA/149/2025HC Karnataka02 Sept 2025

Bench: CHIEF JUSTICE,C M JOSHI

Section 144Section 260

delay in filing the appeal is condoned. 2. The Revenue has filed the present appeal under Section 260-A of the Income Tax Act, 1961 [the Act] impugning an order dated 04.09.2024 passed by the learned Income Tax Appellate Tribunal [ITAT] in MP.No.63/Bang/2023

PR. COMMISSIONER OF INCOME TAX-5 vs. M/S ORIGAMI CELLULO PVT LTD

ITA/726/2023HC Karnataka18 Nov 2025

Bench: B M SHYAM PRASAD,T.M.NADAF

Section 260Section 263Section 92B
Disallowance2
Comparables/TP2
Section 92C

Transfer Pricing risk and when domestic transactions are also part of parameters of TP risk. 2. The appeal is belated by 539 days. The Deputy Commissioner of Income Tax has filed an affidavit in support of the application. Sri E I Sanmathi, the learned counsel for the appellant- Revenue and Sri A Shankar, the learned Senior Counsel for the respondent

THE PR COMMISSIONER OF INCOME TAX-1 vs. ROBERT BOSCH ENGINEERING AND BUSINESS SOLUTIONS PVT LTD

Appeal of the revenue is hereby dismissed

ITA/145/2025HC Karnataka20 Aug 2025

Bench: CHIEF JUSTICE,C M JOSHI

Section 260Section 260ASection 92C

delay of 55 days in filing the above captioned appeal is condoned. 2. The Revenue has filed the present appeal under Section 260A of the Income Tax Act, 1961 [the Act], impugning an order - 3 - HC-KAR NC: 2025:KHC:32339-DB ITA No. 145 of 2025 dated 09.12.2024 [impugned order] passed by the learned Income Tax Appellate Tribunal [ITAT

PR.COMMISSIONER OF INCOMETAX-2 vs. M/S.EYGBS (INDIA) PVT LTD

ITA/107/2025HC Karnataka12 Sept 2025

Bench: CHIEF JUSTICE,C M JOSHI

Section 10ASection 14ASection 260Section 260A

delay of 46 days in filing the above captioned appeals, is condoned. 2. The Revenue have filed the present appeals under Section 260A of the Income Tax Act, 1961 [the Act], impugning a common order dated 08.11.2024 [impugned order], passed by the learned Income Tax Appellate Tribunal [Tribunal] in ITA No.1367/Bang/2024 in respect of the Assessment Year

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

Accordingly, appeal of Revenue is dismissed

ITA/200003/2014HC Karnataka09 Aug 2016

Bench: B.VEERAPPA,VINEET KOTHARI

Section 133ASection 143(3)Section 194CSection 194JSection 201(1)Section 260Section 32Section 40

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