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71 results for “transfer pricing”+ Reopening of Assessmentclear

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Key Topics

Addition to Income63Section 14821Section 14714Section 26011Reopening of Assessment6Section 45(4)4Section 260A3Section 153(3)(ii)3Section 153(1)(a)3

SRI N GOVINDARAJU vs. THE INCOME TAX OFFICER

Appeal stands disposed of

ITA/504/2013HC Karnataka01 Jul 2015

Bench: S.SUJATHA,VINEET SARAN

Section 143(1)Section 147Section 148Section 45(2)

reopening of the assessment and he is not empowered to touch upon any other issue for which no reasons have been recorded. The above interpretation is contrary to the legislative intent. 47.3: Therefore, to articulate the legislative intention clearly Explanation 3 has been inserted in S.147 to provide that the Assessing Officer may examine, assess or reassess any issue relevant

M/S SYSARRIS SOFTWARE PVT LTD vs. THE DEPUTY COMMISSIONER OF INCOME TAX

WA/3039/2012HC Karnataka

Showing 1–20 of 71 · Page 1 of 4

Section 45(2)3
Capital Gains3
Transfer Pricing2
07 Jan 2013

Bench: A Learned Single Judge Of This Court By Filing A Writ Petition On The Premise That There Was No Tangible Or Credible Information With The Assessing Officer Before Issuing The Notice Under Section 148 Of The Act.

Section 148Section 4

transfer pricing officer for the other assessment year cannot be a basis for reopening of any concluded assessments of other

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

WP/30388/2015HC Karnataka10 Aug 2018

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

Section 143Section 147Section 148

reopening the issue for the - 10 - current Assessment Year 2009-10 fortifies that it is nothing but the change of opinion made by the AO. Learned Counsel argued that there must be consistency in the orders of the Authorities passed while exercising quasi judicial functions. For the previous years as well as for the subsequent years, the assessments are concluded

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

M/S PATEL MARIGOWDA AND BROS., vs. THE COMMISSIONER OF INCOME TAX

The appeal is dismissed

ITA/490/2006HC Karnataka16 Jul 2012

Bench: B.MANOHAR,K.SREEDHAR RAO

Section 148Section 260Section 45(4)

transfer, section 45(4) can apply to levy capital gains on such distribution? Without prejudice whether on the facts and in the circumstances of the case the appellate Tribunal was justified in holding that the provisions of section 45(4) are applicable to the assessee firm for the assessment year 96- 97? Whether on the facts and in the circumstances

PR.COMMISSIONER OF INCOME TAX-7 vs. M/S TALLY INDIA PVT LTD

In the result, we do not find

ITA/307/2018HC Karnataka06 Apr 2021

Bench: ALOK ARADHE,M.G.S. KAMAL

Section 143(2)Section 153(1)(a)Section 153(3)(ii)Section 260Section 260ASection 92C

Transfer Pricing Officer by an order dated 13.06.2012 after affording an opportunity to the assessee passed an draft order of assessment on 05.07.2012 and forwarded the same to the assessee on 11.07.2012. The assessee filed an objection before the Dispute Resolution Panel on 09.08.2012. Thereafter, the Dispute Resolution Panel passed an order on 22.04.2013. The Assessing Officer passed a final

MRS ANITA GOVERDHAN LOEBBERT vs. THE INCOME TAX OFFICER

Appeals are allowed;

ITA/334/2018HC Karnataka10 Jan 2023

Bench: P.S.DINESH KUMAR,G BASAVARAJA

Section 260

reopening of the assessment and the consequent assessment proceedings are valid in law on the facts and circumstance of the case? 3. Whether the Tribunal was justified in law in not adjudicating the issue of cost of the capital asset on 01.04.1981 and consequential indexed cost of acquisition to be allowed on the facts and circumstances of the case

MRS MONIKA GOVERDHAN vs. THE INCOME TAX OFFICER

Appeals are allowed;

ITA/332/2018HC Karnataka10 Jan 2023

Bench: P.S.DINESH KUMAR,G BASAVARAJA

Section 260

reopening of the assessment and the consequent assessment proceedings are valid in law on the facts and circumstance of the case? 3. Whether the Tribunal was justified in law in not adjudicating the issue of cost of the capital asset on 01.04.1981 and consequential indexed cost of acquisition to be allowed on the facts and circumstances of the case

SRI B V S MURTHY vs. THE INCOME TAX OFFICER

The appeal is disposed of

ITA/397/2010HC Karnataka19 Feb 2020

Bench: ALOK ARADHE,RAVI V HOSMANI

Section 147Section 148Section 17(2)(iii)Section 260Section 260A

reopening for the Assessment Years 1998-99 and 1999-2000 held that stock option cannot be assessed as perquisite. It was further held that the gains could be assessed only as capital gains and the appellant was the owner of shares that were sold for more than 12 months. Being aggrieved, the revenue filed an appeal. The tribunal vide impugned

M/S PADMINI PRODUCTS (P) LTD., vs. THE DEPUTY COMMISSIONER OF INCOME TAX

In the result, the aforesaid

ITA/154/2014HC Karnataka05 Oct 2020

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 147Section 148Section 260Section 260ASection 32(1)Section 43(1)

reopened under Section 147 of the Act on the ground that during the course of the proceeding for Assessment Year 2007-08, it was noticed by the Assessing Officer that assessee had made claim of depreciation on intangible assets, which was not in accordance with Section 32(1) of the Act. Thereafter, a notice under Section

THE PR. COMMISSIONER OF INCOME TAX vs. M/S GOLDMAN SACHS SERVICES PVT LTD

ITA/29/2019HC Karnataka10 Jun 2021

Bench: The Hon'Ble Mr. Justice V. Srishananda Civil Revision Petition No.29/2019 Between

Section 115Section 37(2)

transferred from IDBI Bank to Akash Ranka’s account in Karur Vysya Bank as an interim measure to enable the firm to pay the outstanding bills for smooth functioning of the work. 35 28. Such an admission in the statement of objection would be sufficient enough to hold that there was misdeed committed by the first respondent detrimental

M/S.V S LAD & SONS vs. STATE OF KARNATAKA

WP/17002/2010HC Karnataka03 Dec 2015

Bench: B.V.NAGARATHNA,SUBHRO KAMAL MUKHARJEE (AG.CJ)

transferred from Entry 19 of List II (State List) of Seventh Schedule of the Constitution to Entry 17A of List III (Concurrent List) of the said Schedule and on the enforcement of Forest (Conservation) Act, 1980 (hereinafter, referred to as ‘F.C. Act’, for the sake of convenience) and the provisions made under the Environment (Protection Act), 1986 (hereinafter, referred

M/S GARUDADHRI IMPEX PVT. LTD.,., vs. STATE OF KARNATAKA

WP/39190/2010HC Karnataka03 Dec 2015

Bench: B.V.NAGARATHNA,SUBHRO KAMAL MUKHARJEE (AG.CJ)

transferred from Entry 19 of List II (State List) of Seventh Schedule of the Constitution to Entry 17A of List III (Concurrent List) of the said Schedule and on the enforcement of Forest (Conservation) Act, 1980 (hereinafter, referred to as ‘F.C. Act’, for the sake of convenience) and the provisions made under the Environment (Protection Act), 1986 (hereinafter, referred

M/S KARIGANUR MINERAL MINING INDUSTRY vs. STATE OF KARNATAKA

WP/15991/2010HC Karnataka03 Dec 2015

Bench: B.V.NAGARATHNA,SUBHRO KAMAL MUKHARJEE (AG.CJ)

transferred from Entry 19 of List II (State List) of Seventh Schedule of the Constitution to Entry 17A of List III (Concurrent List) of the said Schedule and on the enforcement of Forest (Conservation) Act, 1980 (hereinafter, referred to as ‘F.C. Act’, for the sake of convenience) and the provisions made under the Environment (Protection Act), 1986 (hereinafter, referred

SMT K M PARVATHAMMA vs. STATE OF KARNATAKA

WP/16144/2010HC Karnataka03 Dec 2015

Bench: B.V.NAGARATHNA,SUBHRO KAMAL MUKHARJEE (AG.CJ)

transferred from Entry 19 of List II (State List) of Seventh Schedule of the Constitution to Entry 17A of List III (Concurrent List) of the said Schedule and on the enforcement of Forest (Conservation) Act, 1980 (hereinafter, referred to as ‘F.C. Act’, for the sake of convenience) and the provisions made under the Environment (Protection Act), 1986 (hereinafter, referred

M/S.HIND TRADERS vs. THE STATE OF KARNATAKA

WP/31185/2008HC Karnataka03 Dec 2015

Bench: B.V.NAGARATHNA,SUBHRO KAMAL MUKHARJEE (AG.CJ)

transferred from Entry 19 of List II (State List) of Seventh Schedule of the Constitution to Entry 17A of List III (Concurrent List) of the said Schedule and on the enforcement of Forest (Conservation) Act, 1980 (hereinafter, referred to as ‘F.C. Act’, for the sake of convenience) and the provisions made under the Environment (Protection Act), 1986 (hereinafter, referred

M/S CANARA MINERALS PRIVATE LIMITED vs. STATE OF KARNATAKA

WP/13803/2008HC Karnataka03 Dec 2015

Bench: B.V.NAGARATHNA,SUBHRO KAMAL MUKHARJEE (AG.CJ)

transferred from Entry 19 of List II (State List) of Seventh Schedule of the Constitution to Entry 17A of List III (Concurrent List) of the said Schedule and on the enforcement of Forest (Conservation) Act, 1980 (hereinafter, referred to as ‘F.C. Act’, for the sake of convenience) and the provisions made under the Environment (Protection Act), 1986 (hereinafter, referred

SRI H G RANGANGOUD vs. STATE OF KARNATAKA

WP/17001/2010HC Karnataka03 Dec 2015

Bench: B.V.NAGARATHNA,SUBHRO KAMAL MUKHARJEE (AG.CJ)

transferred from Entry 19 of List II (State List) of Seventh Schedule of the Constitution to Entry 17A of List III (Concurrent List) of the said Schedule and on the enforcement of Forest (Conservation) Act, 1980 (hereinafter, referred to as ‘F.C. Act’, for the sake of convenience) and the provisions made under the Environment (Protection Act), 1986 (hereinafter, referred

M/S M HANUMANTH RAO vs. STATE OF KARNATAKA & OTHERS

WP/31266/2008HC Karnataka03 Dec 2015

Bench: B.V.NAGARATHNA,SUBHRO KAMAL MUKHARJEE (AG.CJ)

transferred from Entry 19 of List II (State List) of Seventh Schedule of the Constitution to Entry 17A of List III (Concurrent List) of the said Schedule and on the enforcement of Forest (Conservation) Act, 1980 (hereinafter, referred to as ‘F.C. Act’, for the sake of convenience) and the provisions made under the Environment (Protection Act), 1986 (hereinafter, referred

M/S NADEEM MINERALS, vs. STATE OF KARNATAKA & OTHERS

WP/31149/2008HC Karnataka03 Dec 2015

Bench: B.V.NAGARATHNA,SUBHRO KAMAL MUKHARJEE (AG.CJ)

transferred from Entry 19 of List II (State List) of Seventh Schedule of the Constitution to Entry 17A of List III (Concurrent List) of the said Schedule and on the enforcement of Forest (Conservation) Act, 1980 (hereinafter, referred to as ‘F.C. Act’, for the sake of convenience) and the provisions made under the Environment (Protection Act), 1986 (hereinafter, referred