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5 results for “reassessment u/s 147”+ Transfer Pricingclear

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Key Topics

Section 14814Section 1479Section 244A5Section 143(3)4Section 143(2)4Section 2603Section 92C3Section 45(4)2Reopening of Assessment

WIPRO LIMITED vs. THE JOINT COMMISSIONER OF INCOME TAX

WP/20040/2019HC Karnataka25 Aug 2021

Bench: The Hon’Ble Mr. Justice Krishna S.Dixit Writ Petition No.20040/2019 (T-It) Between:

Section 1Section 143(2)Section 143(3)Section 244ASection 254Section 92C

transfer pricing adjustment actually was not determinative of the refund inasmuch as the tax 8 amount was paid based on book profit, as provided u/s 115JB; the entitlement of the assessee for interest u/s 244A(1A) is intended to bring parity in the converse situation where the Revenue levies interest on delayed payment of taxes as provided u/s 234B

M/S T T K PRESTIGE LTD vs. THE DEPUTY COMMISSIONER OF INCOME TAX

2
Deduction2
Transfer Pricing2
Addition to Income2
WP/30388/2015
HC Karnataka
10 Aug 2018

Bench: The Hon’Ble Mrs.Justice S.Sujatha

Section 143Section 147Section 148

reassess was brought to the notice - 8 - of the Court, arguing that, on concluding the assessment under section 143[3] of the Act, with all the material facts available on record, the presumption u/s. 114[e] of the Indian Evidence Act, 1872 would be that the AO has looked into all the aspects of the matter made available

THE COMMISSIONER OF INCOME TAX vs. M/S SHASTHA PHARMA LABORATORIES

The appeal is dismissed

ITA/331/2007HC Karnataka27 Nov 2013

Bench: N.KUMAR,RATHNAKALA

Section 143(3)Section 147Section 148Section 2Section 260Section 45Section 45(4)

price of Rs.50.12/- lakhs did not amount to a transfer and consequently, no capital gains tax was liable to be paid.?” 7. However, before commencement of the arguments, learned Counsel for the revenue sought the permission of the Court to raise additional substantial question of law : “Whether the Tribunal was correct in holding the reopening of assessment under Sections 147

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

u/s 10AA Profit of the undertaking as per computation statement 43,60,79,542 - 7 - HC-KAR NC: 2025:KHC:36360-DB ITA No. 107 of 2025 C/W ITA No. 106 of 2025 Add: Voluntary TP adjustment 36,90,62,637 Income from business of the undertaking after voluntary TP adjustment 80,51,42,179 7. The AO had denied

NOVO NORDISK INDIA PRIVATE LIMITED vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 12 (2

WP/21206/2014HC Karnataka25 Jun 2018

Bench: S.SUJATHA

Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 149Section 152Section 92B(2)Section 92C

Transfer Pricing Officer under Section 92CA(1) of the Act for determination of arm’s length price in respect of international transactions - 4 - reported by the petitioner during the subject Assessment year. TPO passed a detailed order under Section 92CA(3) of the Act accepting the arm’s length price reported by the petitioner in respect of its international transactions