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5 results for “transfer pricing”+ Rectification u/s 154clear

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Key Topics

Section 26012Section 244A5Section 10A3Section 2632Section 143(3)2Addition to Income2

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

Rectification Order on 26.03.2018 g) Assessee follows up his application dated 18.01.2008 u/s 154 before AO with: i) Application u/s 154 dated 24.1.2018 ii) Application u/s 154 dated 3.4.2018 iii) Letter dated 17.5.2018 iv) Letter dated 22.3.2019 43 v) Impugned order 29.3.19 (ii) A careful analysis of the order of ITAT dated 4.1.2018 would reveal that the ITAT dealt with

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

The appeals stand disposed of, accordingly

ITA/881/2008HC Karnataka25 Mar 2015

Bench: N.KUMAR,B.SREENIVASE GOWDA

Section 260

Rectification order was passed on - 18 - 19.02.2002 and the income was determined at Rs.114,72,43,817/- u/s 143(1) read with Section 154. Notice u/s 142(1) was issued on 21.12.2001 with a questionnaire. Further notices u/s 142 (1) were issued on various dates beginning from 7.10.2003 to 8.3.2004. The assessee- company filed written replies along with enclosures from

THE COMMISSIONER OF INCOME TAX vs. M/S WIPRO LTD

The appeals stand disposed of, accordingly

ITA/211/2009HC Karnataka25 Mar 2015

Bench: N.KUMAR,B.SREENIVASE GOWDA

Section 260

Rectification order was passed on - 18 - 19.02.2002 and the income was determined at Rs.114,72,43,817/- u/s 143(1) read with Section 154. Notice u/s 142(1) was issued on 21.12.2001 with a questionnaire. Further notices u/s 142 (1) were issued on various dates beginning from 7.10.2003 to 8.3.2004. The assessee- company filed written replies along with enclosures from

PR.COMMISSIONER OF vs. M/S TRIANZ HOLDINGS PVT LTD

ITA/551/2016HC Karnataka03 Jul 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 10ASection 260

transfer pricing adjustments may be recalculated accordingly.” Further, while disposing off of the assessee’s petition for rectification of its earlier directions issued through order u/s 144C (5) of the Act dated 3.12.2014, the DRP, in its Order u/s 154

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

In the result, the assessee's appeal for

ITA/433/2018HC Karnataka20 May 2025

Bench: V KAMESWAR RAO,S RACHAIAH

Section 143(3)Section 144CSection 260Section 263

154 of the IT Act, has erred in stating that - 10 - ITA No. 433 of 2018 Assessment Order 29.10.2012 is completely silent on the issue, which is in contrast to the decision of the Bengaluru Bench of the Tribunal in ICICI Venture Funds Management Co. Ltd. Vs. CIT (ITA No.66/Bang/2010), wherein it has been held that merely because there