INGRAM MICRO INDIA PVT.LTD. vs. THE STATE OF KARNATAKA

Of the Department's clouded interpretation of the Centum

Bench: ANAND BYRAREDDY

20 of the next month or even later depending upon the location of the supplier in the State of Karnataka and or actual despatch of goods by its supplier. In such cases, the petitioners will account for the purchases only in the next month after conducting the quantity and quality checks. Therefore, the month in which the goods are accounted

M/S. HINDUSTAN COCA COLA vs. STATE OF KARNATAKA

Of the Department's clouded interpretation of the Centum

Bench: ANAND BYRAREDDY

20 of the next month or even later depending upon the location of the supplier in the State of Karnataka and or actual despatch of goods by its supplier. In such cases, the petitioners will account for the purchases only in the next month after conducting the quantity and quality checks. Therefore, the month in which the goods are accounted

INGRAM MICRO INDIA PVT. LTD. vs. THE STATE OF KARNATAKA

Of the Department's clouded interpretation of the Centum

Bench: ANAND BYRAREDDY

20 of the next month or even later depending upon the location of the supplier in the State of Karnataka and or actual despatch of goods by its supplier. In such cases, the petitioners will account for the purchases only in the next month after conducting the quantity and quality checks. Therefore, the month in which the goods are accounted

M/S. HINDUSTAN COCA COLA vs. STATE OF KARNATAKA

Of the Department's clouded interpretation of the Centum

Bench: ANAND BYRAREDDY

20 of the next month or even later depending upon the location of the supplier in the State of Karnataka and or actual despatch of goods by its supplier. In such cases, the petitioners will account for the purchases only in the next month after conducting the quantity and quality checks. Therefore, the month in which the goods are accounted

DEPA INDIA PRIVATE LTD. vs. THE STATE OF KARNATAKA

Of the Department's clouded interpretation of the Centum

Bench: ANAND BYRAREDDY

20 of the next month or even later depending upon the location of the supplier in the State of Karnataka and or actual despatch of goods by its supplier. In such cases, the petitioners will account for the purchases only in the next month after conducting the quantity and quality checks. Therefore, the month in which the goods are accounted

SONAL APPAREL PRIVATE LTD., vs. THE STATE OF KARNATAKA

Of the Department's clouded interpretation of the Centum

Bench: ANAND BYRAREDDY

20 of the next month or even later depending upon the location of the supplier in the State of Karnataka and or actual despatch of goods by its supplier. In such cases, the petitioners will account for the purchases only in the next month after conducting the quantity and quality checks. Therefore, the month in which the goods are accounted

M/S INDIA MOTOR PARTS & ACCESSORIES LTD vs. THE DEPUTY COMMISSIONER OF

Of the Department's clouded interpretation of the Centum

Bench: ANAND BYRAREDDY

20 of the next month or even later depending upon the location of the supplier in the State of Karnataka and or actual despatch of goods by its supplier. In such cases, the petitioners will account for the purchases only in the next month after conducting the quantity and quality checks. Therefore, the month in which the goods are accounted

THE PRINCIPAL COMMISSIONER vs. M/S OBULAPURAM MINING

Bench: K.SOMASHEKAR,UMESH M ADIGA

Transfer Pricing Officer and subsequently an order under Section 92CA came to be passed on 23.01.2013 making the following adjustment to the admitted value of international transactions. 5 (a) In respect of sale of iron ore 111,48,68,440/- (b) In respect of Helicopter Hiring Charges 72,23,641/- Total adjustments Rs.112,20,92,081/- 7. It is further

PR COMMISSIONER OF vs. M/S SOFTBRANDS INDIA

Bench: S.SUJATHA,VINEET KOTHARI

20. From a bare comparison of the provisions quoted above and as discussed in various judgments of the Constitutional Courts, which we will refer in brief herein below, it is clear that the Scheme of both Section 260-A in Income Tax Act, 1961 and Section 100 r/w. Section 103 of the Code of Civil Procedure are in pari materia

PR COMMISSIONER OF vs. M/S SOFTBRANDS INDIA

Bench: S.SUJATHA,VINEET KOTHARI

20. From a bare comparison of the provisions quoted above and as discussed in various judgments of the Constitutional Courts, which we will refer in brief herein below, it is clear that the Scheme of both Section 260-A in Income Tax Act, 1961 and Section 100 r/w. Section 103 of the Code of Civil Procedure are in pari materia

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

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

Transfer Pricing in International Transactions. Further vide the 2016 amendment, the right to appeal was specifically taken away in order to minimize these disputes. 16. Once the DRP has exercised its power under Section 144C of the Act, the Commissioner loses his jurisdiction to 14 exercise power under Section 263 of the Act. Consequently, the Commissioner cannot issue a show

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

In the result, the appeal fails and is hereby dismissed

Bench: ALOK ARADHE,R. NATARAJ

20,07,861/-, disallowance under Section 14A read with Rule 8D(2)(iii) to the extent of Rs.20,51,175/- and disallowance of Rs.74,08,964/- under the provisions of Section 80JJAA of the Act were proposed. The 5 assessee thereupon filed objections before the Dispute Resolution Panel contesting all the additions. The Dispute Resolution Panel, however rejected the objections

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

In the result, both the writ petitions are

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.

Transfer Pricing Officer passed order under Section 92CA of IT Act on 30.01.2015 for the assessment year 2011-12. Subsequently, the respondent-Revenue passed draft assessment order under Section 144C read with Section 143(2) of the IT Act on 27.03.2015. Against the said draft assessment order, appellant filed objections/appeal before the DRP and the DRP after hearing, passed order

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

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

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

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

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

Bench: CHIEF JUSTICE,C M JOSHI

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