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304 results for “transfer pricing”+ Section 108clear

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Key Topics

Addition to Income60Section 26011Section 92B3Section 1093Section 43Section 65(1)3Section 633Section 92C2Section 13(1)(e)2

PR. COMMISSIONER OF INCOME TAX-5 vs. M/S ORIGAMI CELLULO PVT LTD

ITA/726/2023HC Karnataka18 Nov 2025

Bench: B M SHYAM PRASAD,T.M.NADAF

Section 260Section 263Section 92BSection 92C

Transfer Pricing risk and when domestic transactions are also part of parameters of TP risk. 2. The appeal is belated by 539 days. The Deputy Commissioner of Income Tax has filed an affidavit in support of the application. Sri E I Sanmathi, the learned counsel for the appellant- Revenue and Sri A Shankar, the learned Senior Counsel for the respondent

PR. COMMISSIONER OF INCOME TAX-2 vs. M/S TT STEEL SERVICE INDIA PVT LTD

ITA/665/2023HC Karnataka14 Oct 2024

Bench: V KAMESWAR RAO,S RACHAIAH

Showing 1–20 of 304 · Page 1 of 16

...
Revision u/s 2632
Section 260Section 92Section 92BSection 92C

Section 92CA could be invalid and bad in law. 7. It is for this precise reason, tribunal has rightly held that order passed by the TPO and DRP is unsustainable in the eyes of law. The said finding is based on the authoritative principles enunciated by the Hon’ble Supreme Court in Kolhapur Canesugar Works Ltd referred to herein supra

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

Appeal is dismissed with costs

ITA/70/2007HC Karnataka26 Sept 2012

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

Section 100

price paid or promised or part-paid and part-promised. Sale how made.— 3Such transfer, in the case of tangible immoveable property of the value of one hundred rupees and upwards, or in the case of a reversion or other intangible thing, can be made only by a registered instrument. 1In the case of tangible immoveable property of a value

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

ITA/512/2017HC Karnataka23 Jul 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 2(22)(e)Section 254Section 260

108/- per share having face value of only `10/- per share and therefore the payment made by the Assessee - Indian Company over and above the fair market price of the shares of the Assessee would not be treated as part of the purchase price because, the transaction is between the two closely related parties

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

SATISH KUMAR PANDEY vs. ASSISTANT COMMISSIONER OF INCOME TAX

Appeals are allowed

ITA/696/2019HC Karnataka16 Dec 2022

Bench: P.S.DINESH KUMAR,T.G. SHIVASHANKARE GOWDA

Section 143(3)Section 260Section 48

Section 108 of the Companies Act, 1956 any member desiring to sell any of his shares must notify to the Directors of the number of shares, the fair value and the name of the proposed transferee and the Board must offer to the other shareholders, the shares offered, at the fair value and if the offer is accepted, the shares

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

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 along with enclosures from time to time. The return furnished on 30.10.2001 was processed u/s 143(3) of the I.T.Act on 24.03.2004 and order was passed

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

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 along with enclosures from time to time. The return furnished on 30.10.2001 was processed u/s 143(3) of the I.T.Act on 24.03.2004 and order was passed

M/S INDUS TOWERS LTD vs. THE DEPUTY COMMISSIONER OF COMMERCIAL TAXES

In the result, we pass the following order:

WA/3403/2011HC Karnataka07 Sept 2011

Bench: RAVI MALIMATH,N.KUMAR

Section 4

Section 66 thereof created charge of service tax in regard to taxable services. Service Lax’ is defined in clause (34) of Set lion 65 to mean tax chargeable under the provLsioi is of that napler. 7’axable ceri’icc is dejrnea Iunder sub ‘‘larcsc’ Ib) 1 ½usc 4 1 [ 5j 0 n ° mc a an, srvkc provided tu. znrcr cilia

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

108 to 117 of the IPC. 12. The Apex Court in a recent judgment in the case of U.SUBHADRAMMA v. STATE OF A.P. – (2016) 7 SCC 797 deprecate the action of the competent criminal Court to have conducted the trial on the ground that the charges are already framed against the accused. It is held that once the 14 accused

L. VENKATARAMANA RAJU vs. UNION OF INDIA

WP/53718/2017HC Karnataka21 Apr 2022

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

Section 96

Price Advisory Committee which has been approved by the Board in its 356th meeting held on 20.09.2018, that the compensation shall be awarded at Rs.50 Lakhs per acre on consent and if the land owners are not agreeable for such consent awards, the award shall be made in accordance with law. The Board has filed objections to the said application

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

WP/43206/2018HC Karnataka21 Apr 2022

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

Section 96

Price Advisory Committee which has been approved by the Board in its 356th meeting held on 20.09.2018, that the compensation shall be awarded at Rs.50 Lakhs per acre on consent and if the land owners are not agreeable for such consent awards, the award shall be made in accordance with law. The Board has filed objections to the said application

SMT. S. JALAJA vs. UNION OF INDIA

In the result, writ appeals are allowed

WA/1105/2019HC Karnataka24 Aug 2021

Bench: ALOK ARADHE,HEMANT CHANDANGOUDAR

Section 4

section 107 (2) and Article 254 (2) is that when there is legislation covering the same ground both by 119 the Centre and by the Province, both of them being competent to enact the same, the law of the Centre should prevail over that of the State". "It is true, as already pointed out, that on a question under Article

HINDUSTAN CALCINED METALS PRIVATE LIMITED vs. STATE OF KARNATAKA

In the result, these petitions must succeed

WP/46232/2016HC Karnataka04 Oct 2017

Bench: ABHAY SHREENIWAS OKA (CJ),P.S.DINESH KUMAR

price of forest produce was within the legislative competence of the State under Entry 54 of List-II and constitutionally valid. Although the unamended section 98A(1) refers to the levy of a tax, the impost is more in the nature of a fee. The amount collected by way of forest development tax is earmarked for development and regeneration

M/S PADMAVATHI FERROUS LTD vs. GOVERNMENT OF KARNATAKA

In the result, these petitions must succeed

WP/49694/2016HC Karnataka04 Oct 2017

Bench: ABHAY SHREENIWAS OKA (CJ),P.S.DINESH KUMAR

price of forest produce was within the legislative competence of the State under Entry 54 of List-II and constitutionally valid. Although the unamended section 98A(1) refers to the levy of a tax, the impost is more in the nature of a fee. The amount collected by way of forest development tax is earmarked for development and regeneration

M/S ELECTROTHERM (INDIA)LTD vs. THE STATE OF KARNATAKA

In the result, these petitions must succeed

WP/51110/2016HC Karnataka04 Oct 2017

Bench: ABHAY SHREENIWAS OKA (CJ),P.S.DINESH KUMAR

price of forest produce was within the legislative competence of the State under Entry 54 of List-II and constitutionally valid. Although the unamended section 98A(1) refers to the levy of a tax, the impost is more in the nature of a fee. The amount collected by way of forest development tax is earmarked for development and regeneration

M/S. BMM ISPAT LTD vs. THE STATE OF KARNATAKA

In the result, these petitions must succeed

WP/43969/2016HC Karnataka04 Oct 2017

Bench: ABHAY SHREENIWAS OKA (CJ),P.S.DINESH KUMAR

price of forest produce was within the legislative competence of the State under Entry 54 of List-II and constitutionally valid. Although the unamended section 98A(1) refers to the levy of a tax, the impost is more in the nature of a fee. The amount collected by way of forest development tax is earmarked for development and regeneration

IRON ORE END USERS ASSOCIATION vs. STATE OF KARNATAKA

In the result, these petitions must succeed

WP/43951/2016HC Karnataka04 Oct 2017

Bench: ABHAY SHREENIWAS OKA (CJ),P.S.DINESH KUMAR

price of forest produce was within the legislative competence of the State under Entry 54 of List-II and constitutionally valid. Although the unamended section 98A(1) refers to the levy of a tax, the impost is more in the nature of a fee. The amount collected by way of forest development tax is earmarked for development and regeneration

SATHVAHANA ISPAT LIMITED vs. STATE OF KARNATAKA

In the result, these petitions must succeed

WP/43871/2016HC Karnataka04 Oct 2017

Bench: ABHAY SHREENIWAS OKA (CJ),P.S.DINESH KUMAR

price of forest produce was within the legislative competence of the State under Entry 54 of List-II and constitutionally valid. Although the unamended section 98A(1) refers to the levy of a tax, the impost is more in the nature of a fee. The amount collected by way of forest development tax is earmarked for development and regeneration

M/S JEEVAKA INDUSTRIES PRIVATE LIMITED vs. STATE OF KARNATAKA

In the result, these petitions must succeed

WP/53987/2016HC Karnataka04 Oct 2017

Bench: ABHAY SHREENIWAS OKA (CJ),P.S.DINESH KUMAR

price of forest produce was within the legislative competence of the State under Entry 54 of List-II and constitutionally valid. Although the unamended section 98A(1) refers to the levy of a tax, the impost is more in the nature of a fee. The amount collected by way of forest development tax is earmarked for development and regeneration