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

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:

2) of the Act, a reference was made to the Transfer Pricing Officer (hereafter ‘TPO’) qua the international transactions; the TPO in exercise of power u/s 92C(A) carried out an aggregate adjustment of Rs.10,54,52,192/-; the first respondent-Joint Commissioner of Income Tax (hereafter 'JCIT') had proposed a Draft Assessment Order dated 28.12.2011 u/s 143

PR COMMISSIONER OF vs. M/S SOFTBRANDS INDIA

Bench: S.SUJATHA,VINEET KOTHARI

2) An appeal may lie under this section from an appellate decree passed ex- parte. Date of Judgment 25-06-2018 I.T.A.No.536/2015 C/w I.T.A.No.537/2015 Pr. Commissioner of Income Tax & Anr. Vs. M/s. Softbrands India P. Ltd., 35/80 (3) In an appeal under this section, the memorandum of appeal shall precisely state the substantial question of law involved

PR COMMISSIONER OF vs. M/S SOFTBRANDS INDIA

Bench: S.SUJATHA,VINEET KOTHARI

2) An appeal may lie under this section from an appellate decree passed ex- parte. Date of Judgment 25-06-2018 I.T.A.No.536/2015 C/w I.T.A.No.537/2015 Pr. Commissioner of Income Tax & Anr. Vs. M/s. Softbrands India P. Ltd., 35/80 (3) In an appeal under this section, the memorandum of appeal shall precisely state the substantial question of law involved

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(2

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

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

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

SRI N GOVINDARAJU vs. THE INCOME TAX OFFICER

Appeal stands disposed of

Bench: S.SUJATHA,VINEET SARAN

143(1) of the Act and accepted on 2.3.2005. Thereafter, notice under Section 148 was issued on 17.1.2006 stating that the assessee had converted agricultural land into non- agricultural purposes, formed sites and sold the same during the relevant period, and while arriving at the capital gains, the assessee had considered the indexation up to the financial year

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

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

2. This is the second round of litigation, as much as, the challenge made to the Notice dated 11.02.2014 [Annexure-G]. In the first round of litigation, Petitioner-Assessee had challenged the Notice as well as the Order dated 6.1.2015 issued by the Respondent, rejecting the objections of the petitioner to the notice under section 148 of the Act. This

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

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

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 PR. COMMISSIONER OF INCOME TAX vs. M/S CISCO SYSTEMS

The appeals are allowed; the impugned

Bench: SATISH CHANDRA SHARMA,R. NATARAJ

price for which it is sold, so, however, that where the actual cost of a motor car is, in accordance with the proviso to clause (1) of section 43, taken to be twenty-five thousand rupees, the moneys payable in respect of such motor car shall be taken to be a sum which bears to the amount for which

LAHAR SINGH SIROYA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

The appeal stands allowed

Bench: S.SUJATHA,VINEET SARAN

143(1) of the Act but the Assessing Officer subsequently issued notice under Section 148 of the Act, and the assessment was finalized by an assessment order dated 31.12.2008 wherein the sale amount was treated as short term capital gains, instead of long term capital gains as had been claimed by the assessee. The appeal filed by the assessee

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

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

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

Section 143(2) was issued on 19.09.2008 upon the assessee. Since there were 3 international transactions carried out by the QGSL, a reference was made to Transfer Pricing

THE COMMISSIONER OF INCOME TAX vs. ING VYSYA BANK LTD

In the result, this appeal is allowed in part,

Bench: B.MANOHAR,D.V.SHYLENDRA KUMAR

143 (2) of the Act as the Assessing Officer, prima facie found that many deductions, exemptions etc., as by way of expenditure or otherwise claimed by the Assessee were not admissible. 5 4. One such claim for deduction was the claim of the assessee for a sum of Rs.1,09,10,252/- to be allowed as loss, in the wake