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802 results for “transfer pricing”+ Section 1clear

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Key Topics

Section 26091Addition to Income32Transfer Pricing26Section 260A22Comparables/TP21Deduction18Section 92C17Section 10A14Section 14A

THE PRINCIPAL COMMISSIONER vs. M/S OBULAPURAM MINING

ITA/100012/2017HC Karnataka17 Mar 2023

Bench: K.SOMASHEKAR,UMESH M ADIGA

Section 143(3)Section 144CSection 144C(13)Section 260ASection 37(1)Section 92ASection 92C

transfer pricing officer for 32 determination of arms- length price(ALP). The copy of above instruction has not been provided to the assessee. (b) Referring to Section 92CA(1

DEVAS MULTIMEDIA PRIVATE LIMITED vs. THE PRINCIPAL COMMISSIONER OF INCOME-TAX

Showing 1–20 of 802 · Page 1 of 41

...
12
Section 10B12
Disallowance11
Section 143(3)8
WP/11618/2016
HC Karnataka
27 Sept 2019

Bench: The Hon’Ble Mr.Justice P.B. Bajanthri Writ Petition No.11618 Of 2016 (T-It) Between:

Section 142(4)Section 143(2)Section 143(3)Section 144Section 144CSection 263Section 92C

price under this section, exercise all or any of the powers specified in clauses (a) to (d) of sub-section (1) of section 131 or sub-section (6) of section 133 (or Section 133A). Explanation:- For the purposes of this section, “Transfer

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

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 u/s 143(1

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

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 u/s 143(1

PR COMMISSIONER OF vs. M/S SOFTBRANDS INDIA

ITA/537/2015HC Karnataka25 Jun 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 260

Transfer Pricing/ determination of the ‘Arm’s Length Price’; [II] The Scheme of procedure of assessment and appeals to the Tribunal and High Court/Supreme Court. [III] The scope of interference by High Court under Section 260-A of the Act in these type of cases. Findings of the Tribunal: 12. We find it appropriate to quote some portions

PR COMMISSIONER OF vs. M/S SOFTBRANDS INDIA

ITA/536/2015HC Karnataka25 Jun 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 260

Transfer Pricing/ determination of the ‘Arm’s Length Price’; [II] The Scheme of procedure of assessment and appeals to the Tribunal and High Court/Supreme Court. [III] The scope of interference by High Court under Section 260-A of the Act in these type of cases. Findings of the Tribunal: 12. We find it appropriate to quote some portions

PR COMMISSIONER OF INCOME TAX-5 vs. M/S PAGE INDUSTRIES LTD

In the result, the appeal fails and is hereby dismissed

ITA/285/2017HC Karnataka08 Jan 2021

Bench: ALOK ARADHE,R. NATARAJ

Section 143(2)Section 14ASection 260Section 80JSection 92C

Transfer Pricing Officer has gone into the provision of Section 92A(2) of the Act. It is further submitted that the provisions of sub- Sections (1

SHRI. PARSWANATH vs. ASSISTANT COMMISSIONER OF INCOME TAX

ITA/304/2019HC Karnataka13 Sept 2021

Bench: The Hon'Ble Mr. Justice M. Nagaprasanna

Section 109Section 13(1)(e)Section 13(2)Section 397Section 482

price in buying or selling. [Wharton's Law Lexicon, 1976 Reprint Ed.]. Expression “abatement” has been separately spelt out, in the same dictionary. “Abatement of criminal proceedings” has been termed to mean their termination 26 without a decision on the merits and without the assent of the prosecutor. If this is the legal position or meaning of abatement

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

section (254, 263,264 orders) Post 01.04.2019, If the order is received after 01.04.2019, then in such cases the time limit has been increased to 12 months 153(4) Notwithstandi ng sub-sec, (1), (2) & (3), where a reference has been made to Transfer Pricing

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)

Section 43(1) of the Act is that the Assessing Officer 20 has to establish that the main purpose of the transfer of such asset was reduction of liability to income tax by claiming extra depreciation on enhanced cost. IN order to establish aforesaid fact, it has to be established that apart from claiming additional depreciation on enhanced cost there

MR. BINEESH KODIYERI vs. DIRECTORATE OF ENFORCEMENT

WP/13261/2020HC Karnataka16 Mar 2021

Bench: The Hon’Ble Mr. Justice Suraj Govindaraj Writ Petition No. 13261 Of 2020 (Gm-Res) Between: Mr. Bineesh Kodiyeri S/O Mr. Kodiyeri Balakrishnan Aged About 37 Years Kootamvilla Lane, Maruthankuzhi Thiruvananthapuram District Kerala State – 695013

Section 19Section 482

price of which exceeds on e crore rupees; or (d) Fraudulently availing of or attempt to avail of drawback or any exemption from duty provided under this Act, if the amount of drawback or exemption from duty exceeds fifty lakh rupees. WP No. 13261 of 2020 65 (7) Save as otherwise provided in sub-section (6), all other offences under

THE COMMR OF INCOME TAX vs. NIKE INC

Appeals are dismissed

ITA/976/2008HC Karnataka07 Mar 2013

Bench: B.MANOHAR,N.KUMAR

Section 260A

price, quality, quantity, to whom to be shipped and billed. The local manufacturer in India is conveyed of the decision by the office in USA and once it is accepted, the local manufacturer carries on his activity. The liaison office keeps a close watch on the progress, quality, etc., at the manufacturing workshop. The liaison office also keeps a watch

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

In the result, the appeals are partly allowed

ITA/133/2007HC Karnataka23 Aug 2013

Bench: B.MANOHAR,DILIP B.BHOSALE

Section 260

price of transfer for the purpose of computation of deduction u/s.80HH and 80I of the Act? A-10. Whether the Tribunal was correct in holding that excise duty and sales tax should not be included in the total turnover for the purpose of computation of deduction u/s.80HHC of the Act? 6. In all the three appeals, the following question

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

Transfer Pricing Officer and to avoid rigors of Section 92C(4) of the Act and consequently enhanced benefits under section 10AA of the Act"? (ii) "Whether on facts and circumstances of the case, the Tribunal's order can be said as perverse in nature in not appreciating that the assesee failed to substantiate an furnish details

SMT. M R PRABHAVATHY vs. THE DEPUTY COMMISSIONER OF INCOME TAX

WTA/1/2019HC Karnataka04 Mar 2020

Bench: The Hon’Ble Mr. Justice K.Natarajan Election Petition No.1 Of 2019 Connected With Election Petition No.2 Of 2019

Section 81

Section 33A of RP Act and 106 he has committed corrupt practice of bribery as contemplated under Sections 123(1)(A), 123(1)(B), 123(7), 123(7)(b), 123(vii)(d), 123(7)(h) and Section 123(8), 123(3), 3A and 123(6) of R.P. Act ? The petitioner in E.P. No.2/2019 has contended that respondent No.1 committed corrupt

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

THE MANGALORE ELECTRICITY SUPPLY COMPANY LTD., vs. SRI A CHANDRASEKHAR

WP/15230/2022HC Karnataka17 Oct 2022

Bench: G.NARENDAR,P.N.DESAI

price fixed under any law, etc. 29. Deficiency of service is defined under Section 2(1)(g) of the Consumer Protection Act, 1986 in the following manner: “2. (1)(g) ‘deficiency’ means any fault, imperfection, shortcoming or inadequacy in the quality, nature and manner of performance which is required to be maintained by or under any law for the time

M/S SREE JAYALAKSHMI TEXTILES vs. M/S INTERNATIONAL ASSET RECONSTRUCTION

WP/22348/2015HC Karnataka15 Dec 2015

Bench: The Date Fixed For Sale Of Transfer & In Such Event The Secured Asset Shall Not Be Sold & That Once The Auction Sale Process Is Commenced & The Property Is Auctioned & Sold On The Date Fixed For Sale & The Sale In Favour Of The Highest Bidder Is Confirmed & 25%

Section 13(8)

1) Notwithstanding anything contained in section 69 or section 69A of the Transfer of Property Act, 1882 (4 of 1882), any security interest created in favour of any secured creditor may be enforced, without the intervention 16 of court or tribunal, by such creditor in accordance with the provisions of this Act. (2) Where any borrower, who is under

M/S SREE JAYALAKSHMI TEXTILES vs. M/S INTERNATIONAL ASSET RECONSTRUCTION

WP/29362/2015HC Karnataka15 Dec 2015

Bench: The Date Fixed For Sale Of Transfer & In Such Event The Secured Asset Shall Not Be Sold & That Once The Auction Sale Process Is Commenced & The Property Is Auctioned & Sold On The Date Fixed For Sale & The Sale In Favour Of The Highest Bidder Is Confirmed & 25%

Section 13(8)

1) Notwithstanding anything contained in section 69 or section 69A of the Transfer of Property Act, 1882 (4 of 1882), any security interest created in favour of any secured creditor may be enforced, without the intervention 16 of court or tribunal, by such creditor in accordance with the provisions of this Act. (2) Where any borrower, who is under

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

In the result, both the writ petitions are

ITA/571/2017HC Karnataka04 Jun 2025

Bench: This Court Under Section 260A Of The Income-Tax Act, 1961 (For Short “It Act”), Questioning The Order Dated 21.06.2017 In It(Tp)A No.807/Bang/2016 Passed By Income Tax Appellate Tribunal, “B” Bench, Bengaluru (For Short “Tribunal”), Dismissing The Appeal Refusing To Declare The Proceedings Under Section 144C Of The It Act As Null & Void.

Section 143(1)Section 143(2)Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 260Section 260ASection 92C

1) of the IT Act and notice under Section 143(2) of the IT Act was issued calling upon certain details/information from the appellant. Thereafter, the case of the appellant was referred to Transfer Pricing