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 u/s 143(1

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 u/s 143(1

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:

143(1) and 144. 21 months From AY 2018-19, time limit has been amended to 18 months From AY 2019-20, time limit has been further reduced to 12 months 153(2) Income escapement assessment To assess/re- assess/ recompute under section 147 NA 12 months from the end of FY in which notice under section 148 was served. From

PR COMMISSIONER OF vs. M/S SOFTBRANDS INDIA

Bench: S.SUJATHA,VINEET KOTHARI

1) (d) of the Act. Section 254 of the Act empowers the Appellate Tribunal to pass such orders on the appeals ‘as it thinks fit’ after giving an opportunity of hearing to both the parties. 38. From the aforesaid Scheme of assessment with regard to international transactions, it is clear that the process of determination of ‘Arm’s Length Price

PR COMMISSIONER OF vs. M/S SOFTBRANDS INDIA

Bench: S.SUJATHA,VINEET KOTHARI

1) (d) of the Act. Section 254 of the Act empowers the Appellate Tribunal to pass such orders on the appeals ‘as it thinks fit’ after giving an opportunity of hearing to both the parties. 38. From the aforesaid Scheme of assessment with regard to international transactions, it is clear that the process of determination of ‘Arm’s Length Price

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

1)(2), BANGALORE. ... APPELLANTS (BY SRI. JEEVAN J. NEERALGI, ADV.,) AND: M/S. PAGE INDUSTRIES LTD ABBAIAH REDDY INDUSTRIAL AREA JOCKEY CAMPUS, NO.6/2 & 6/4 HONGASANDRA, BEGUR HOBLI BANGALORE-560068 PAN: AABCP2K630D. ... RESPONDENT (BY SRI. CHYTHANYA K.K. ADV.) - - - THIS I.T.A. IS FILED UNDER SEC. 260-A OF INCOME TAX ACT 1961, ARISING OUT OF ORDER DATED 24.06.2016 PASSED

SHRI. PARSWANATH vs. ASSISTANT COMMISSIONER OF INCOME TAX

Bench: The Hon'Ble Mr. Justice M. Nagaprasanna

143 15 7. This case is referred to in Jamuna Singh case [AIR 1967 SC 553: 1967 Cri LJ 541] and it is held that: (AIR headnote) “[I]t cannot be held in law that a person cannot ever be convicted of abetting a certain offence when the person alleged to have committed that offence in consequence of the abetment

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 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

MR. BINEESH KODIYERI vs. DIRECTORATE OF ENFORCEMENT

Bench: The Hon’Ble Mr. Justice Suraj Govindaraj Writ Petition No. 13261 Of 2020 (Gm-Res) Between: Mr. Bineesh Kodiyeri S/O Mr. Kodiyeri Balakrishnan Aged About 37 Years Kootamvilla Lane, Maruthankuzhi Thiruvananthapuram District Kerala State – 695013

price of which exceeds on e crore rupees; or (d) Fraudulently availing of or attempt to avail of drawback or any exemption from duty provided under this Act, if the amount of drawback or exemption from duty exceeds fifty lakh rupees. WP No. 13261 of 2020 65 (7) Save as otherwise provided in sub-section (6), all other offences under

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

Bench: S.SUJATHA

1) of the Act on 11.9.2007. The case of the petitioner was selected for detailed scrutiny and notice under 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

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.

1) of the IT Act and notice under Section 143(2) of the IT Act was issued calling upon certain details/information from the appellant. Thereafter, the case of the appellant was referred to Transfer Pricing

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

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 92C of the Act on 11.01.2011. This court in W.P.No.45313/2011 by an order dated 08.12.2011 restrained the Transfer Pricing Officer from proceeding to pass a draft

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

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

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

1) of the Act for passing an order under Section 143(3) of 7 Order dated 7.9.2020 passed in WP No.32699/2019 8 Judgment dated 31.3.2022 passed in WA No.1120/2021 & c/w matters. - 7 - NC: 2024:KHC:32486-DB ITA No. 527 of 2022 C/W ITA No. 528 of 2022 the Act and held that the order under Section 143

PR. COMMISSIONER OF INCOME TAX-5 vs. M/S. PUMA SPORTS INDIA P., LTD.,

The appeal stands dismissed

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

143(3) read with Section 144(C)(13) of the Income Tax Act, 1961 (hereinafter referred to as ‘Act’) by making transfer pricing adjustment for Rs.4,16,65,106/- on the basis of the order passed under Section 92CA of the Act dated 24.10.2016. The assessing authority also made other additions. The assessee’s objections were not considered