THE PR COMMISSIONER OF INCOME TAX vs. M/S E4E BUSINESS SOLUTIONS INDIA PVT LTD.,

Bench: S.SUJATHA,VINEET KOTHARI

transfer pricing officer has rightly chosen the said comparable in accordance with provisions of the Act? (2) Whether on facts and in the circumstances of the case, the Tribunal erred in allowing holding that the telecommunication charges excluded from export turnover should also be excluded from total turnover by relying on the decision in the case of Tata Elxsi

PR. COMMISSIONER OF INCOME TAX-2 vs. M/S TT STEEL SERVICE INDIA PVT LTD

Bench: V KAMESWAR RAO,S RACHAIAH

Transfer Pricing Adjustment to International Transaction with Associated Enterprises only even when same is contrary to Section 92CA of the Act and when assesse is providing service to both AE and Non-AE's where assesse has not made any bifurcation of profit in book of account as overall profit margin is recorded in books without any data

THE PR COMMISSIONER OF INCOME TAX vs. M/S BROCADE COMMUNICATION

Bench: S.SUJATHA,VINEET KOTHARI

exemption from payment of income tax, export should earn foreign exchange. It does not mean that the undertaking should personally export goods manufactured / software developed by it outside the country. It may export out of India by itself or export out of India through any other STP Unit. Once the goods manufactured by the assessee is shown to have Date

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 of Rs.6,02,14,066/- and advance tax payment of Rs.59,50,80,000/-. The assessee claimed refund of Rs.17,12,21,725/-. The return of income was processed

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 of Rs.6,02,14,066/- and advance tax payment of Rs.59,50,80,000/-. The assessee claimed refund of Rs.17,12,21,725/-. The return of income was processed

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

Bench: ARAVIND KUMAR,SURAJ GOVINDARAJ

transfer pricing order under Section 92CA of the Act to determine arms length price as the assessee had entered into specified domestic transaction and on the 4 ground it was covered under Section 92BA of the Act. Despite objections being filed by the assessee before Dispute Resolution Panel (for short ‘DRP’) directions came to be issued

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

Bench: CHIEF JUSTICE,C M JOSHI

transfer pricing [TP] adjustments of ₹14,82,00,000/-, which was reworked at ₹21,36,91,000/- on - 6 - HC-KAR NC: 2025:KHC:36360-DB ITA No. 107 of 2025 C/W ITA No. 106 of 2025 account of APA. Similarly, the Assessee had along with his return, made TP adjustments

THE PR COMMISSIONER OF INCOME TAX CIT(A) vs. M/S AMD INDIA PVT. LTD.,

The appeal is dismissed

Bench: S SUNIL DUTT YADAV,B.S PATIL

transfer price adjustment apart from adjusting export turnover by reducing communication expenses and foreign currency expenditure for the purpose of computing deduction under Section 10A. This was approved by DRP and after considering the objections filed, he directed the Assessing Officer not to keep a cap on working capital adjustment and also directed not to reduce the foreign travel expenditure

M/S INDUS TOWERS LTD vs. THE DEPUTY COMMISSIONER OF COMMERCIAL TAXES

In the result, we pass the following order:

Bench: RAVI MALIMATH,N.KUMAR

exemption from paqmnent would not militate against the concept qf transfer of the right (.o use the goods.” Atain, the Apex Court in the case of ASSOCIATION OF LEASING AND FINANCIAL SERVICE COMPANIES VS. UNION OF IJDIA AND OTHERS reported in. (201.1) 2 13CC 352, at “35-: Accoratno Ic- Chirtu on Contract, a hire pu.rch.ase reement is a vehicle

THE PR COMMISSIONER OF INCOME TAX vs. M/S EXIDE LIFE INSURANCE COMPANY LTD

In the result, both the appeals stand dismissed

Bench: S.SUJATHA,RAVI V HOSMANI

Transfer Pricing Officer (TPO) to determine the Arm’s Length Price and the said officer did not suggest TP adjustment. Assessing Authority made non TP addition pertaining to surplus from shareholders account, treating the same as income from other business and losses from pension fund not allowed to be carried forward. Aggrieved by the said order, the assessee preferred appeals

THE PR COMMISSIONER OF INCOME TAX vs. M/S EXIDE LIFE INSURANCE CO LTD

In the result, both the appeals stand dismissed

Bench: S.SUJATHA,RAVI V HOSMANI

Transfer Pricing Officer (TPO) to determine the Arm’s Length Price and the said officer did not suggest TP adjustment. Assessing Authority made non TP addition pertaining to surplus from shareholders account, treating the same as income from other business and losses from pension fund not allowed to be carried forward. Aggrieved by the said order, the assessee preferred appeals

M/S. EVERGREEN HARDWARE STORES vs. THE ASSISTANT COMMISSIONER OF

Appeal is allowed

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

exempt income earned is Rs.2,12,146/-. He contended that in order to disallow a portion of the expenditure, the Assessing Officer ought to have satisfied himself that the suo moto disallowance made is incorrect. Without recording such satisfaction, the Assessing Officer could not have arbitrarily disallowed the amount of Rs.53,367/- by invoking Rule 8D of the Rules

M/S BHORUKA ENGINEERING INDS. LTD vs. THE DEPUTY COMMISSIONER OF INCOME TAX

Appeal is allowed

Bench: B.MANOHAR,N.KUMAR

transferring of shares to claim exemption under Section 10(38) of the Act and therefore he submits the order passed by the authorities are valid and legal and does not call for any interference. 12. From the material on record, it is clear the 30 acres of land in White Field belong to Bhoruka Steel Limited (BSL). It became

PR COMMISSIONER OF vs. M/S TELELOGIC INDIA PVT LTD

Bench: S.SUJATHA,VINEET KOTHARI

Transfer Pricing Officer has rightly chosen the same by applying qualitative and quantitative filters?” 3. Regarding 1st substantial question of law:- Learned counsel for the appellants-Revenue has submitted that the Hon'ble Supreme Court has settled the controversy in the case of Commissioner of Income-tax V/s. Yokogawa India Ltd., [(2017) 77 taxmann.com 41 (SC)] and therefore the said

THE PR COMMISSIONER OF vs. M/S ARIBA TECHNOLOGIES INDIA

Bench: ABHAY SHREENIWAS OKA (CJ),S SUNIL DUTT YADAV

Transfer Pricing Officer, the learned Assessing Officer made the Assessment Order dated 28.01.2011. In regard to the claim for deduction under Section 10-A the Act, the Assessing Officer observed that the internet expenses/telecommunication expenses in foreign currency were to be reduced from the export turnover; but did not accept the submissions of the assessee that whatever amount was adjusted/reduced

SRI SRIDHAR vs. THE STATE OF KARNATAKA

Bench: JAYANT PATEL,N.K.SUDHINDRARAO

exemption from tax has been upheld in several decided cases. By parity of reasoning, it can be said that a legislative classification making the burden of the tax heavier in proportion to the increase in turnover would be reasonable. The basis is that just as in taxes upon income or upon transfers at death, so also in imposts upon business

FEDERATION OF WINES MERCHANTS ASSOCIATION vs. THE STATE OF KARNATAKA

Bench: The Hon’Ble Mr.Justice Aravind Kumar

exemption from tax has been upheld in several decided cases. By parity of reasoning, it can be said that a legislative classification making the burden of the tax heavier in proportion to the increase in turnover would be reasonable. The basis is that just as in taxes upon income or upon transfers at death, so also in imposts upon business

SRI M MADHAVA GOWDA vs. UNDER SECRETARY TO GOVERNMENT

Bench: The Hon’Ble Mr.Justice Aravind Kumar

exemption from tax has been upheld in several decided cases. By parity of reasoning, it can be said that a legislative classification making the burden of the tax heavier in proportion to the increase in turnover would be reasonable. The basis is that just as in taxes upon income or upon transfers at death, so also in imposts upon business