PR COMMISSIONER OF vs. M/S SOFTBRANDS INDIA

Bench: S.SUJATHA,VINEET KOTHARI

143, 147 etc. are final and are binding on this Court. While dealing with these appeals under Section 260-A of the Act, we cannot disturb those findings of fact under Section 260-A of the Act, unless such findings are ex-facie perverse and unsustainable and exhibit a total non- application of mind by the Tribunal to the relevant

PR COMMISSIONER OF vs. M/S SOFTBRANDS INDIA

Bench: S.SUJATHA,VINEET KOTHARI

143, 147 etc. are final and are binding on this Court. While dealing with these appeals under Section 260-A of the Act, we cannot disturb those findings of fact under Section 260-A of the Act, unless such findings are ex-facie perverse and unsustainable and exhibit a total non- application of mind by the Tribunal to the relevant

M/S T T K PRESTIGE LTD vs. THE DEPUTY COMMISSIONER OF INCOME TAX

Bench: The Hon’Ble Mrs.Justice S.Sujatha

TRANSFER PRICING OFFICER AND ANOTHER’ [(2010) 320 ITR 565 [DELHI]. [e] ASSISTANT COMMISSIONER OF INCOME TAX AND OTHERS vs. ICICI SECURITIES PRIMARY DEALERSHIP LTD. [2012] 348 ITR 299 (SC) [f] ‘COMMISSIONER OF INCOME TAX vs. I.A.E.C. (PUMPS) LTD.,’ [(1998) 150 CTR SC 126 - 14 - 6. Submissions of the learned Counsel for the Revenue: Learned Counsel Sri. K.V. Aravind appearing

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 on 30.01.2015. Thereafter, the respondent passed draft assessment order under Section 144C read with Section - 4 - HC-KAR NC: 2025:KHC:19558-DB ITA No. 571 of 2017 143

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:

Section 244A(1A) of the Act has styled the operative portion of the impugned order as under: “In this case, the Hon’ble ITAT, Bengaluru has remitted back the issue of Transfer Pricing to the AO for fresh assessment/re-assessment as per Para No. 5 & 6 of the ITAT order. Further, fresh approval has been taken from

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

Section 143(2) of the Act was issued. The Assessing Officer, during the course of the proceedings, found that the 4 assessee - Company had returned the international transaction in Form 3CEB and paid royalty of Rs.6,78,29,024/- to JII. The assessee sought to justify the consideration paid to international transactions entered with

THE COMMISSIONER OF INCOME TAX vs. M/S SHASTHA PHARMA LABORATORIES

The appeal is dismissed

Bench: N.KUMAR,RATHNAKALA

143(3) of the Act and the order dated 11.11.1994, accepting the same should not have issued notice under Section 148 of the Act, which is barred by the first proviso to Section 147 and the proceedings now initiated is void-ab-initio. They also pointed out that the stand of the assessing authority that there has been a dissolution

THE PR. COMMISSIONER OF INCOME TAX CIT(A) vs. M/S IDS SOFTWARE SOLUTIONS INDIA PVT LTD

Bench: ABHAY SHREENIWAS OKA (CJ),S.G.PANDIT

143, 147 etc. are final and are binding on this Court. While dealing with these appeals under Section 260-A of the Act, we cannot disturb those findings of fact under Section 260-A of the Act, we cannot disturb those findings of the fact under Section 260-A of the Act, unless such findings are ex-facie perverse

PR COMMISSIONER OF INCOME TAX vs. M/S TATA POWER SOLAR SYSTEMS LIMITED

Appeals are dismissed at the stage of admission itself as being

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

Section 143(3) of the Act on 27.3.2015, wherein the transfer pricing adjustment was made, as also certain other additions

THE PR. COMMISSIONER OF INCOME TAX vs. M/S EDS ELECTRONICS DATA SYSTEMS INDIA PVT.LTD.

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

Bench: ALOK ARADHE,R. NATARAJ

Section 143(3) of the Act assessed the income at Rs.33,98,72,603/- after making disallowances with regard to addition on account of income from other sources, addition on account of foreign exchange loss and addition on account of Arms 6 Length Price (ALP). 5. The assessee thereupon filed an appeal before the Commissioner of Income Tax (Appeals

PR.COMMISSIONER OF INCOME TAX-7 vs. M/S TEXPORT OVERSEAS PVT LTD

Bench: ARAVIND KUMAR,SURAJ GOVINDARAJ

143(3) r/w Section 144C(13) of Income Tax Act, 1961 (for short ‘Act’) came to be passed on 30.06.2017 whereby the assessing officer had made transfer pricing

PR.COMMISSIONER OF INCOME TAX-7 vs. M/S TALLY INDIA PVT LTD

In the result, we do not find

Bench: ALOK ARADHE,M.G.S. KAMAL

143(2) of the Act was issued to the assessee on 08.09.2009. Thereafter, the case was referred to the Transfer Pricing Officer (TPO) for computation of Arms Length Price (ALP) under 4 Section

NOVO NORDISK INDIA PRIVATE LIMITED vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 12 (2

Bench: S.SUJATHA

Section 143(2) was issued on 23.10.2007, to which the petitioner filed requisite reply. Reference was also made with the prior approval of respondent No.2 to the Transfer Pricing

THE DIRECTOR OF INCOME-TAX vs. M/S. INTEL CAPITAL (CAYMAN) CORPORATION

In the result, the appeal fails and is hereby

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

143(3) read with Section 144C of the Act, the Assessing Authority, vide order dated 18.02.2011 inter alia held that assessee had acquired foreign currency convertible bonds and after conversion of the same into shares, sold the same during the relevant previous year and disclosed short term capital gains from the transaction and paid tax thereon at the prescribed rate

COMMISSIONER OF INCOME TAX-III vs. M/S YODLEE INFOTECH PVT LTD

The appeal is disposed of

Bench: ALOK ARADHE,M.I.ARUN

143(1) of the Act and was subsequently taken up for scrutiny. As the International transactions of the assessee were in excess of Rs.10 Crores, a reference under Section 92CA(1) of the Act was made to Transfer Pricing

THE PR.COMMISSIONER OF INCOME TAX vs. M/S. YOKOGAWA INDIA LTD

The appeal is dismissed

Bench: S.G.PANDIT,K. V. ARAVIND

143(2) of the Act. In view of the international transactions, the Assessing Officer referred the matter to the Transfer Pricing Officer (TPO) for determination of the arm’s length price. The TPO, by order dated 29.01.2016 passed under Section

M/S PADMINI PRODUCTS (P) LTD., vs. THE DEPUTY COMMISSIONER OF INCOME TAX

In the result, the aforesaid

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

143(2) and 142(1) of the Act was issued to the assessee. The Assessing Officer by an order dated 31.12.2010 inter alia held that intangible assets valued in the hands of the company at the time of succession, were valued as per assessee’s 6 own valuation and not for any actual consideration. It was further held that assessee

M/S AMD FAR EAST LTD., vs. THE JOINT DIRECTOR OF INCOME-TAX

Bench: S.SUJATHA,RAVI V HOSMANI

Transfer Pricing Officer [TPO] for determining arm’s length price under Section 92CA of the Act. On receipt of the order passed under Section 92CA Act, the respondent passed the draft assessment order under Section 143