PR COMMISSIONER OF vs. M/S SOFTBRANDS INDIA

Bench: S.SUJATHA,VINEET KOTHARI

Transfer Pricing Officer, the Assessee Company within 30 days can either accept the said Draft Order or file its objections before the Dispute Resolution Panel (DRP) and the Assessing Officer as per Section 144

PR COMMISSIONER OF vs. M/S SOFTBRANDS INDIA

Bench: S.SUJATHA,VINEET KOTHARI

Transfer Pricing Officer, the Assessee Company within 30 days can either accept the said Draft Order or file its objections before the Dispute Resolution Panel (DRP) and the Assessing Officer as per Section 144

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.

144-C does not envisage or contemplate the interdiction or involvement of the transfer pricing officer once a directive has been framed by the Dispute Resolution Panel. The role of the transfer pricing officer comes to an end once an order as contemplated under Section

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:

144; therefore these terminologies have different import in different sections. In the light of this discussion, it is clear that the term “assessment” is used in section 153(1) to mean the entire process of assessment; section 153(2) uses the words, ‘assessment’, ‘reassessment’ or ‘recomputation’ but in respect of section 147 which deals with income escaping assessment; section

PR. COMMISSIONER OF INCOME TAX-2 vs. TOYOTA TSUSHO INDIA PRIVATE LIMITED

Bench: CHIEF JUSTICE,C M JOSHI

transfer pricing adjustment at `25,23,76,521/- in the trading segment. 6. In so far as manufacturing segment is concerned, the learned TPO determined the arms length PLI at 3.45% and accordingly made in adjustment of `6,02,89,351/- for the manufacturing segment

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

144- C(13) r/w Section 143(3) of the Act on 27.3.2015, wherein the transfer pricing adjustment was made, as also

SIMPLILEARN SOLUTIONS PRIVATE LIMITED vs. DEPUTY COMMISSIONER OF INCOME TAX

Bench: The Hon’Ble Mr. Justice B. M. Shyam Prasad

Transfer Pricing Officer’s order dated 28.01.2021 (Annexure-A), the draft Assessment Order dated 23.04.2021 (Annexure-B), and the Dispute Resolution Panel’s order dated 24.01.2022 (Annexure-C). 2. Sri T. Suryanarayana, learned Senior counsel for the petitioner, submits that the petitioner is constrained to impugn these orders/demands because the petitioner has not been extended complete opportunity of hearing

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

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

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

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

Section 145A of the Income- tax Act which was inserted with effect from assessment year 1999-2000. The said provision states that the valuation of stock should include the amount of any tax duty, cess or fee - 94 - actually paid or incurred to bring the goods to its present location and condition. The Department has followed a consistent stand

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

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

Section 145A of the Income- tax Act which was inserted with effect from assessment year 1999-2000. The said provision states that the valuation of stock should include the amount of any tax duty, cess or fee - 94 - actually paid or incurred to bring the goods to its present location and condition. The Department has followed a consistent stand

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

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

144 C(13) of the IT Act. This Court must advert to the indisputable facts before the rival submissions are considered. 3. The Dispute Resolution Panel [DRP], in exercise of its jurisdiction under Section 144C[6] of the IT Act, has issued certain directions on 24.11.2015. The Transfer Pricing

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

The appeal stands dismissed

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

Section 144(C)(13) of the Income Tax Act, 1961 (hereinafter referred to as ‘Act’) by making transfer pricing adjustment

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

Bench: S.SUJATHA,VINEET KOTHARI

144 C (5) of the Income Tax Act, 1961, the Assessee Company preferred an appeal before the learned Income Tax Appellate Tribunal (ITAT), who disposed of the said appeal by the impugned Order dated 22/02/2017. Date of Judgment :23-07-2018 I.T.A.No.512/2017 M/s. Fidelity Business Services India Pvt. Ltd., Vs. Assistant Commissioner of Income-Tax, & Anr. 7/86

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

In the result, we pass the following order:

Bench: RAVI MALIMATH,N.KUMAR

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

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

The appeals are allowed; the impugned

Bench: SATISH CHANDRA SHARMA,R. NATARAJ

144(C) of the Act of 1961 on 12.10.2012, wherein the assessing officer has disallowed the excess depreciation claimed on networking equipments. 3. The Principal Commissioner of Income Tax, Bengaluru, thereafter issued a notice under Section 263 of the Act of 1961 on 5.3.2015 and called upon the assessee to explain as to why the assessment order passed

THE PR. COMMISSIONER OF INCOME TAX (4) vs. M/S CHAMUNDI WINERY AND DISTILLERY

Bench: S.SUJATHA,VINEET KOTHARI

144 (SC) 01-03 2 Godhra Electricity Co. Ltd Vs. CIT 225 ITR 746 (SC) 04-11 13 CIT Vs. Chemosyn Ltd 371 ITR 427 (Bom) 75-79 14 Poorna Electric Supply Co. Ltd Vs. CIT [1965] 56 ITR 521 (SC) 80-85 17 CIT Vs. Chamanlal Mangaldas & Co. 39 ITR 8 (SC) 101-104 18 CIT Vs. Chamanlal Mangaldas

PR. COMMISSIONER OF INCOME TAX vs. M/S CHAMUNDI WINERY AND DISTILLERY

Bench: S.SUJATHA,VINEET KOTHARI

144 (SC) 01-03 2 Godhra Electricity Co. Ltd Vs. CIT 225 ITR 746 (SC) 04-11 13 CIT Vs. Chemosyn Ltd 371 ITR 427 (Bom) 75-79 14 Poorna Electric Supply Co. Ltd Vs. CIT [1965] 56 ITR 521 (SC) 80-85 17 CIT Vs. Chamanlal Mangaldas & Co. 39 ITR 8 (SC) 101-104 18 CIT Vs. Chamanlal Mangaldas

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