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

In the result, I proceed to pass the following:

Bench: The Hon’Ble Mr.Justice Aravind Kumar

disallow such claim made by the assessee though duly certified by the prescribed authority by taking recourse to the later portion of sub-clause (ii) of sub-section (4) of Section 43 of the Act. He would summarise his 9 submissions by contending the definition of ‘scientific research’ found in Section 43(4) has been imported to Section

M/S AMD FAR EAST LTD., vs. THE JOINT DIRECTOR OF INCOME-TAX

Bench: S.SUJATHA,RAVI V HOSMANI

144C [5] of the Act by the DRP. Pursuant to which final assessment order was passed disallowing - 4 - deduction under Section 37[1] of the Act in respect of expatriate costs incurred by the assessee’s permanent establishment. Being aggrieved, the assessee preferred appeal before the Tribunal which came to be rejected. Hence, the present appeal. 4. Learned counsel

MPHASIS LIMITED vs. THE DEPUTY COMMISSIONER OF INCOME TAX

Bench: The Hon’Ble Mr.Justice B. Veerappa Writ Petition No.13313 Of 2017 (T-It)

144C(13) of the Act determining the total income of the petitioner at `524,81,23,820/-and total tax payable as per the assessment order at `191,88,91,064/-. Aggrieved by the said assessment order the petitioner has filed an appeal before the Tribunal and the same is pending. The petitioner also filed an application under Section

XIAOMI TECHNOLOGY INDIA PRIVATE LIMITED vs. DEPUTY COMMISSIONER OF INCOME TAX

In the result, I pass the following:

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

disallowed. On 10.08.2022, petitioner submitted a detailed response along with documents and contested the said Notice and proceedings. - 6 - 2.3 On 11.08.2022, upon obtaining approval from the 3rd respondent, the 1st respondent passed the impugned order under Section 281B of the I.T.Act provisionally attaching the subject fixed deposits of the petitioner in a sum of INR 3,700 crores

PR.COMMISSIONER OF INCOME TAX-7 vs. M/S TEXPORT OVERSEAS PVT LTD

Bench: ARAVIND KUMAR,SURAJ GOVINDARAJ

144C(13) of Income Tax Act, 1961 (for short ‘Act’) came to be passed on 30.06.2017 whereby the assessing officer had made transfer pricing adjustment and other additions. Assessing authority (for short ‘AO’) has made a reference to transfer pricing order under Section 92CA of the Act to determine arms length price as the assessee had entered into specified domestic

HERBALIFE INTERNATIONAL INDIA PVT LTD vs. THE COMMISSIONER OF INCOME TAX

In the result, the assessee's appeal for

Bench: V KAMESWAR RAO,S RACHAIAH

144C of the IT Act. The Assessing Officer in the assessment order determined the total income of the appellant as Rs.4,42,53,130/- after making adjustments to the returned loss by the appellant in the revised return dated 31.03.2010. The Assessing Officer thereafter issued a notice dated 19.08.2013 under Section 154 of the IT Act proposing to rectify

DELL INDIA PVT LTD vs. THE JOINT COMMISSIONER OF INCOME TAX

Bench: The Hon’Ble Mr.Justice Aravind Kumar

144C of the Act came to be passed on 31.01.2014, Annexure-H. Being aggrieved by the same petitioner is said to have filed an appeal and same is filed before first appellate authority and same is pending. 3. First respondent has issued a notice under section 148 of the Income Tax Act to the petitioner-assessee on 27.03.2014 Annexure

THE COMMISSIONER OF INCOME TAX vs. M/S HIMALAYA DRUG COMPANY

Bench: S.SUJATHA,RAVI V HOSMANI

10 - the Act or the draft assessment order passed by the JCIT u/s 144C(1) of the Act? F. Whether on the facts and in the circumstances of the case, the Honourable ITAT was right in law in upholding the initiation of proceedings under section 153C though the requisition proceedings are invalid? G. Whether on the facts

THE COMMISSIONER OF INCOME TAX vs. M/S HIMALAYA DRUG COMPANY

Bench: S.SUJATHA,RAVI V HOSMANI

10 - the Act or the draft assessment order passed by the JCIT u/s 144C(1) of the Act? F. Whether on the facts and in the circumstances of the case, the Honourable ITAT was right in law in upholding the initiation of proceedings under section 153C though the requisition proceedings are invalid? G. Whether on the facts

THE COMMISSIONER OF INCOME TAX vs. M/S HIMALAYA DRUG COMPANY

Bench: S.SUJATHA,RAVI V HOSMANI

10 - the Act or the draft assessment order passed by the JCIT u/s 144C(1) of the Act? F. Whether on the facts and in the circumstances of the case, the Honourable ITAT was right in law in upholding the initiation of proceedings under section 153C though the requisition proceedings are invalid? G. Whether on the facts

M/S. HIMALAYA DRUG COMPANY vs. THE DEPUTY COMMISSIONER OF INCOME TAX

Bench: S.SUJATHA,RAVI V HOSMANI

10 - the Act or the draft assessment order passed by the JCIT u/s 144C(1) of the Act? F. Whether on the facts and in the circumstances of the case, the Honourable ITAT was right in law in upholding the initiation of proceedings under section 153C though the requisition proceedings are invalid? G. Whether on the facts

THE COMMISSIONER OF INCOME TAX vs. M/S HIMALAYA DRUG COMPANY

Bench: S.SUJATHA,RAVI V HOSMANI

10 - the Act or the draft assessment order passed by the JCIT u/s 144C(1) of the Act? F. Whether on the facts and in the circumstances of the case, the Honourable ITAT was right in law in upholding the initiation of proceedings under section 153C though the requisition proceedings are invalid? G. Whether on the facts

THE COMMISSIONER OF INCOME TAX vs. M/S HIMALAYA DRUG COMPANY

Bench: S.SUJATHA,RAVI V HOSMANI

10 - the Act or the draft assessment order passed by the JCIT u/s 144C(1) of the Act? F. Whether on the facts and in the circumstances of the case, the Honourable ITAT was right in law in upholding the initiation of proceedings under section 153C though the requisition proceedings are invalid? G. Whether on the facts