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

Of the Department's clouded interpretation of the Centum

Bench: ANAND BYRAREDDY

price of goods sold to the end consumer. The 24 object of the Act is achieved by allowing dealers to deduct the input tax paid by him on purchases from their output tax liability on sales effected by them, thereby ensuring that tax is levied only on the incremental monetary value addition on each sale of goods. Section 10

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

Of the Department's clouded interpretation of the Centum

Bench: ANAND BYRAREDDY

price of goods sold to the end consumer. The 24 object of the Act is achieved by allowing dealers to deduct the input tax paid by him on purchases from their output tax liability on sales effected by them, thereby ensuring that tax is levied only on the incremental monetary value addition on each sale of goods. Section 10

ACE DESIGNERS LIMITED vs. THE STATE OF KARNATAKA

Of the Department's clouded interpretation of the Centum

Bench: ANAND BYRAREDDY

price of goods sold to the end consumer. The 24 object of the Act is achieved by allowing dealers to deduct the input tax paid by him on purchases from their output tax liability on sales effected by them, thereby ensuring that tax is levied only on the incremental monetary value addition on each sale of goods. Section 10

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

Of the Department's clouded interpretation of the Centum

Bench: ANAND BYRAREDDY

price of goods sold to the end consumer. The 24 object of the Act is achieved by allowing dealers to deduct the input tax paid by him on purchases from their output tax liability on sales effected by them, thereby ensuring that tax is levied only on the incremental monetary value addition on each sale of goods. Section 10

DEPA INDIA PRIVATE LTD. vs. THE STATE OF KARNATAKA

Of the Department's clouded interpretation of the Centum

Bench: ANAND BYRAREDDY

price of goods sold to the end consumer. The 24 object of the Act is achieved by allowing dealers to deduct the input tax paid by him on purchases from their output tax liability on sales effected by them, thereby ensuring that tax is levied only on the incremental monetary value addition on each sale of goods. Section 10

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

Of the Department's clouded interpretation of the Centum

Bench: ANAND BYRAREDDY

price of goods sold to the end consumer. The 24 object of the Act is achieved by allowing dealers to deduct the input tax paid by him on purchases from their output tax liability on sales effected by them, thereby ensuring that tax is levied only on the incremental monetary value addition on each sale of goods. Section 10

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

Of the Department's clouded interpretation of the Centum

Bench: ANAND BYRAREDDY

price of goods sold to the end consumer. The 24 object of the Act is achieved by allowing dealers to deduct the input tax paid by him on purchases from their output tax liability on sales effected by them, thereby ensuring that tax is levied only on the incremental monetary value addition on each sale of goods. Section 10

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

29. In the case of Santosh Hazari Vs. Purushottam Tiwari (Deceased) by LRs., [2001] 3 SCC 179, another Three Judges’ Bench of the Honble Supreme Court explained the meaning of the substantial questions of law in paras.11 and 12 in the following manner. “11. Even under the old Section 100 of the Code (pre-1976 amendment), a pure finding

PR COMMISSIONER OF vs. M/S SOFTBRANDS INDIA

Bench: S.SUJATHA,VINEET KOTHARI

29. In the case of Santosh Hazari Vs. Purushottam Tiwari (Deceased) by LRs., [2001] 3 SCC 179, another Three Judges’ Bench of the Honble Supreme Court explained the meaning of the substantial questions of law in paras.11 and 12 in the following manner. “11. Even under the old Section 100 of the Code (pre-1976 amendment), a pure finding

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 Officer” means a Joint Commissioner or Deputy 23 Commissioner or Assistant Commissioner authorized by the Board to perform all or any of the functions of an Assessing Officer specified in sections 92C and 92D in respect of any person or class of persons. 144C. (1) xxxxx (2) xxxxx (b) file his objections, if any, to such variation with

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

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

10. The assessee-company filed its return of income for the assessment year 2004-05 on 31.10.2004 disclosing a total income of Rs.134,86,47,530/- after claiming deduction u/s 10A of the Act to the extent of Rs.881,34,08,342/- The assessee-company also had international transactions with Associated Enterprises, which were referred to the Transfer Pricing Officer

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

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

10. The assessee-company filed its return of income for the assessment year 2004-05 on 31.10.2004 disclosing a total income of Rs.134,86,47,530/- after claiming deduction u/s 10A of the Act to the extent of Rs.881,34,08,342/- The assessee-company also had international transactions with Associated Enterprises, which were referred to the Transfer Pricing Officer

L. VENKATARAMANA RAJU vs. UNION OF INDIA

Bench: The Hon'Ble Mr.Justice S.R.Krishna Kumar

10. Petitioners have contended that they are entitled to compensation under the said Act of 2013 and the impugned awards and the decisions taken by the respondents awarding compensation under the said Act of 1894 are illegal, arbitrary and deserve to be quashed and 17 that the respondents are to be directed to pass awards in favour of the petitioners

M/S SRI BALAJI CORPORATE SERVICES vs. UNION OF INDIA MINISTRY OF FINANCE

Bench: The Hon'Ble Mr.Justice S.R.Krishna Kumar

10. Petitioners have contended that they are entitled to compensation under the said Act of 2013 and the impugned awards and the decisions taken by the respondents awarding compensation under the said Act of 1894 are illegal, arbitrary and deserve to be quashed and 17 that the respondents are to be directed to pass awards in favour of the petitioners

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

29,024/- to JII. The assessee sought to justify the consideration paid to international transactions entered with JII to be at arm's length. 4. The Assessing Officer thereafter referred the matter to the Transfer Pricing Officer, who by an order dated 30.01.2014 inter alia computed the transfer pricing adjustment at Rs.20,20,07,861/- under Section 92CA

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

Bench: CHIEF JUSTICE,C M JOSHI

transfer of profits. 29. Thus, indisputably, the income computed on the basis of ALP would provide a measure of the profits or income derived by the - 21 - HC-KAR NC: 2025:KHC:36360-DB ITA No. 107 of 2025 C/W ITA No. 106 of 2025 activities carried on by an Assessee. The proviso to Section 92C(4) essentially limits exemption

WIPRO LIMITED vs. THE JOINT COMMISSIONER OF INCOME TAX

Bench: The Hon’Ble Mr. Justice Krishna S.Dixit Writ Petition No.20040/2019 (T-It) Between:

29 • Section 153(2A) prior to substitution by Finance Act, 2016 with effect from 01.06.2016. • Section 153(3) post substitution by Finance Act, 2016 with effect from 01.06.2016. The term ‘fresh assessment’ as employed in the above sections is accompanied by the term ‘setting aside or cancelling an assessment’; it may further be noted that section 153(6) is subject