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

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

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

THE COMMISSIONER OF INCOME TAX vs. M/S KARNATAKA CO-OPERATIVE MILK PRODUCERS

Appeal is dismissed with costs

Bench: The Hon’Ble Mr. Justice N.K.Sudhindrarao R.S.A.No.70/2007

100 is to be effected through registered document which invariably supposes that it shall be in writing and 90 sufficient non judicial stamp shall be required. Section 54 of the Transfer of Property Act, reads as under: 54. “Sale” defined.—‘‘Sale” is a transfer of ownership in exchange for a price

M/S METRIX PRECISION COMPONENTS PVT. LIMITED vs. THE DEPUTY COMMISSIONER OF INCOME TAX

In the result, the appeal is allowed

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

100% export oriented undertakings. Section 10A of the Act was introduced to give effect to EXIM policy of the Central Government. Paragraph 6.10 of the aforesaid policy deals with exchange through others and provides that EOU/EHTP/STP/BTP unit may export goods manufactured / software developed by it through another exporter or any other EOU/EHTP/STP/SEZ unit subject to the conditions mentioned in paragraph

PR.COMMISSIONER OF INCOME TAX vs. M/S MARLABS INNOVATIONS PVT LTD

The appeal is disposed of with liberty as prayed for by the learned

Bench: S.G.PANDIT,C.M. POONACHA

Section 260-A of the Income Tax Act, 1961 (for short, ‘the Act’) questioning the correctness and legality of order dated 13.05.2020 passed by the Income Tax Appellate Tribunal, ‘B’ Bench, Bengaluru (for short, ‘Appellate Authority’) in IT(TP)A.No.430/Bang/2015 and CO.No.160/Bang/2015 for the assessment year 2010-11. 3. This Court, admitted the appeal on 11.07.2022 to consider

THE PR COMMISSIONER OF INCOME TAX vs. M/S HEWLETT PACKARD GLOBAL

Bench: S.SUJATHA,VINEET KOTHARI

100 PAN: AAACD 4078L. …RESPONDENT (By Mr. T. SURYANARAYANA, ADV.) THIS I.T.A. IS FILED UNDER SECTION 260-A OF INCOME TAX ACT 1961, PRAYING TO FORMULATE THE SUBSTANTIAL Date of Judgment 05-07-2018 I.T.A.No.351/2017 The Pr. Commissioner of Income-tax, CIT(A) & Anr. Vs. M/s. Hewlett Packard Global Soft Pvt. Ltd., 2/12 QUESTIONS OF LAW STATED ABOVE. ALLOW

THE PR.COMMISSIONER OF INCOME TAX vs. M/S GE INTELLIGENT PLATFORM PVT. LTD.,

Bench: S.SUJATHA,VINEET KOTHARI

100 PAN:AAACG 7573K …RESPONDENT (BY MR.C.K.NANDAKUMAR, ADV.) Date of Judgment 06-07-2018 I.T.A.No.830/2017 The Pr. Commissioner of Income-tax, CIT(A) & Anr. Vs. M/s. GE Intelligent Platform Pvt. Ltd., 2/7 THIS I.T.A IS FILED U/S.260-A OF INCOME TAX ACT, 1961 PRAYING TO FORMULATE THE SUBSTANTIAL QUESTIONS OF LAW STATED ABOVE; ALLOW THE APPEAL AND SET ASIDE

PR COMMISSIONER OF INCOME TAX - 7 vs. M/S TRIANZ HOLDINGS P LTD

Bench: S.SUJATHA,VINEET KOTHARI

Transfer Pricing Adjustments’ made by the concerned authorities below. We consider it appropriate to quote the relevant portions hereunder:- “7.1 The assessee submitted that the comparables, Avani Cincom Technologies, Date of Judgment 04-07-2018 I.T.A.No.616/2017 Pr. Commissioner of Income Tax-7 & Anr. Vs. M/s. Trianz Holdings P. Ltd., 4/9 Celestial Biolabs, Infosys Techologies Ltd, Kals information Systems

COMMISSIONER OF INCOME TAX III vs. M/S TIMKEN ENGINEERING

Bench: S.SUJATHA,VINEET KOTHARI

100. …RESPONDENT (By Mr. A. SHANKAR & Mr. M. LAVA ADVS.) THESE I.T.A.s ARE FILED UNDER SECTION 260-A OF INCOME TAX ACT 1961, PRAYING TO FORMULATE THE SUBSTANTIAL QUESTIONS OF LAW STATED THEREIN. ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 24/02/2012 Date of Judgment 10-07-2018 I.T.A.Nos.253-254/2012 Commissioner of Income

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

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

100% instead of 80%. 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

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

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

100% instead of 80%. 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

THE PR. COMMISSIONER OF INCOME TAX vs. M/S TEJAS NETWORKS LTD

The appeal is disposed of with liberty as prayed for by the learned

Bench: S.G.PANDIT,C.M. POONACHA

100 PAN-AABCT1670M …RESPONDENT (BY SRI. ANNAMALAI.S., ADVOCATE) THIS ITA / INCOME TAX APPEAL IS FILED UNDER SEC.260-A OF INCOME TAX ACT 1961, ARISING OUT OF ORDER DATED 09/02/2022 PASSED IN IT(TP)A NO.694/BANG/ 2016, FOR THE ASSESSMENT YEAR 2011-2012. PRAYING TO FORMULATE THE SUBSTANTIAL QUESTIONS OF LAW STATED THEREIN AND ETC. THIS APPEAL, COMING ON FOR HEARING, THIS

THE PR. COMMISSIONER OF INCOME TAX vs. M/S TEJAS NETWORKS LTD

The appeal is disposed of with liberty as prayed for by the learned

Bench: S.G.PANDIT,C.M. POONACHA

100 PAN-AABCT1670M …RESPONDENT (BY SRI. ANNAMALAI S., ADVOCATE) THIS ITA / INCOME TAX APPEAL IS FILED UNDER SEC.260-A OF INCOME TAX ACT 1961, ARISING OUT OF ORDER DATED 09/02/2022 PASSED IN IT(TP)A NO.621/BANG/ 2016, FOR THE ASSESSMENT YEAR 2011-2012 PRAYING TO FORMULATE THE SUBSTANTIAL QUESTIONS OF LAW STATED THEREIN AND ETC. THIS APPEAL, COMING ON FOR HEARING

XIAOMI TECHNOLOGY INDIA PRIVATE LIMITED vs. DEPUTY COMMISSIONER OF INCOME TAX

In the result, I pass the following:

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

Section 281E of the Income Tax Act, 1961 (for short ‘the I.T.Act’) whereby, pursuant to the approval dated 11.08.2022 of the 3rd respondent – Principal Commissioner of Income Tax, the 1st respondent provisionally attached the subject fixed deposits of the petitioner in a sum INR 3,700 crores viz., i.e. INR 2,600 crores with HSBC Bank and INR 1,100

THE COMMISSIONER OF INCOME-TAX vs. M/S GOOGLE INDIA PVT LTD

Bench: S.SUJATHA,VINEET KOTHARI

100% as compared to the other comparables taken by the TPO. In view of the decisions of the Co- ordinate Benches of the Tribunal, we direct the AO to exclude these two companies from the list of comparables for the purpose of making the transfer pricing adjustment.” 5. In so far as the third substantial question of law raised

THE COMMISSIONER OF INCOME - TAX vs. M/S BIOCON LTD.,

In the result, we do not find any merit in this

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

100. ... RESPONDENT (BY SRI.T.SURYANARAYANA, ADV.) - - - 2 THIS ITA IS FILED UNDER SECTION 260-A OF I.T. ACT, 1961 ARISING OUT OF ORDER DATED 16.07.2013 PASSED IN ITA NO.248/BANG/2010 FOR THE ASSESSMENT YEAR 2004-05, PRAYING TO: (I) FORMULATE THE SUBSTANTIAL QUESTIONS OF LAW STATED ABOVE. (II) ALLOW THE APPEAL AND SET ASIDE THE ORDERS PASSED BY THE ITAT, BANGALORE

THE PR COMMISSIONER OF INCOME TAX vs. M/S INTEVA PRODUCTS

Bench: S.SUJATHA,VINEET KOTHARI

SECTION 260-A OF INCOME TAX ACT 1961, ARISING OUT OF ORDER DATED 20.07.2016 PASSED IN IT[TP]A No.136/BANG/2015, FOR THE ASSESSMENT YEAR 2010-11, ANNEXURE-D, PRAYING TO [i] FORMULATE THE SUBSTANTIAL QUESTIONS OF LAW STATED ABOVE. [ii] ALLOW THE APPEAL AND SET ASIDE THE ORDER PASSED BY THE ITAT, BENGALURU IN IT[TP]A No.136/BANG/2015 DATED

PR COMMISSIONER OF vs. M/S QUANTECH GLOBAL SERVICES LTD

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

Pricing Officer (TPO) vide letter dated 30.11.2009 and during the course of proceeding before the TPO, assessee vide its letter dated 09.06.2010 categorically stated that its registered office was at Hyderabad and it stood merged with Wipro Ltd., pursuant to the scheme of amalgamation approved by the High Court of Andhra Pradesh vide order dated 21.02.2008 and scheme of amalgamation

M/S FIDELITY BUSINESS SERVICES INDIA PVT LTD vs. ASSISTANT COMMISSIONER OF INCOME TAX

Bench: S.SUJATHA,VINEET KOTHARI

transfer of the reserves and surplus to the holding company by avoiding the payment of tax and therefore it will be treated as a colourable device. There are two aspects in this transaction- (i) It is a simple and plain transaction of buy back of shares without having any dispute of price then the same is beyond the scope