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259 results for “transfer pricing”+ Section 145clear

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Key Topics

Addition to Income56Section 26021Section 14A8Section 260A6Section 43Deduction2Disallowance2

THE PR COMMISSIONER OF INCOME TAX-1 vs. ROBERT BOSCH ENGINEERING AND BUSINESS SOLUTIONS PVT LTD

Appeal of the revenue is hereby dismissed

ITA/145/2025HC Karnataka20 Aug 2025

Bench: CHIEF JUSTICE,C M JOSHI

Section 260Section 260ASection 92C

Section 92CA making an transfer pricing adjustment. The learned TPO inter alia adopted the following filter for selection of comparables for the purpose of transfer pricing analysis.  “Companies whose SWD / IT enabled Service is less than 75% of the total operating revenues were excluded The companies whose revenues from software development and related services are more than 75% of their

THE COMMISSIONER OF INCOME TAX vs. M/S PRESTIGE ESTATE PROJECTS PVT LTD

Appeal is hereby dismissed

ITA/84/2010

Showing 1–20 of 259 · Page 1 of 13

...
HC Karnataka
05 May 2020

Bench: ARAVIND KUMAR,SURAJ GOVINDARAJ

Section 142(1)Section 145Section 154Section 260A

145 empowers the Central Government to notify the Accounting Standards to be followed by any class of assessee or in respect of any class of income . In exercise of the said power conferred, Central Government has issued a notification No.S.O. 69 (E), dated 25.01.1996 whereunder the Accounting Standard-I relating to disclosure of accounting policies have been notified

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 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

ITA/211/2009HC Karnataka25 Mar 2015

Bench: N.KUMAR,B.SREENIVASE GOWDA

Section 260

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, CIT(A) vs. M/S DELHI INTERNATIONAL AIRPORT PVT LTD

In the result, we don to find any

ITA/352/2018HC Karnataka25 May 2021

Bench: SATISH CHANDRA SHARMA,R. NATARAJ

Section 14ASection 260A

transfer of the commodity or scripts: Provided that for the purposes of this clause — (a) a contract in respect of raw materials or merchandise entered into by a person in the course of his manufacturing or merchanting business to guard against loss through future price fluctuations in respect of his contracts for actual delivery of goods manufactured

THE COMMISSIONER OF INCOME TAX vs. M/S QUEST GLOBAL ENGINEERING SERVICES PVT. LTD.,

In the result, we don to find any

ITA/133/2015HC Karnataka15 Feb 2021

Bench: ALOK ARADHE,R. NATARAJ

Section 143(1)Section 14ASection 260Section 73

transfer of the commodity or scripts: Provided that for the purposes of this clause — (a) a contract in respect of raw materials or merchandise entered into by a person in the course of his manufacturing or merchanting business to guard against loss through future price fluctuations in respect of his contracts for actual delivery of goods manufactured

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

THE COMMISSIONER OF INCOME TAX, vs. M/S WIPRO GE MEDICAL SYSTEMS LTD

Appeals stand disposed of accordingly

ITA/890/2008HC Karnataka07 Jun 2016

Bench: JAYANT PATEL,B.SREENIVASE GOWDA

Section 260

Section 145 of the Act. Re-Question No.2 7. The learned counsel Mr. K. V. Aravind appearing for the Revenue reiterated the grounds urged before the ITAT and sought for remanding the matter back to the Assessing Officer to examine the issue in the light of the Judgment of the Apex Court in Rotork Controls Case (supra). 27 8. Learned

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

Appeals stand disposed of accordingly

ITA/912/2008HC Karnataka07 Jun 2016

Bench: JAYANT PATEL,B.SREENIVASE GOWDA

Section 260

Section 145 of the Act. Re-Question No.2 7. The learned counsel Mr. K. V. Aravind appearing for the Revenue reiterated the grounds urged before the ITAT and sought for remanding the matter back to the Assessing Officer to examine the issue in the light of the Judgment of the Apex Court in Rotork Controls Case (supra). 27 8. Learned

SHRI A KHADAR BASHA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

Appeal is allowed

ITA/1130/2008HC Karnataka20 Jan 2015

Bench: B.VEERAPPA,N.KUMAR

Section 145(3)Section 260ASection 40

Section 145(3) of the Income tax Act and rejected the accounts maintained by the assessee. Thereafter, he proceeded to value 408.495 MT of rice bran sold by him at the rate - 4 - of Rs.3,890/- per MT based on the average purchase price and thus the difference was arrived at in a sum of Rs.6,58,965/- and that

THE MANGALORE ELECTRICITY SUPPLY COMPANY LTD., vs. SRI A CHANDRASEKHAR

WP/15230/2022HC Karnataka17 Oct 2022

Bench: G.NARENDAR,P.N.DESAI

price fixed under any law, etc. 29. Deficiency of service is defined under Section 2(1)(g) of the Consumer Protection Act, 1986 in the following manner: “2. (1)(g) ‘deficiency’ means any fault, imperfection, shortcoming or inadequacy in the quality, nature and manner of performance which is required to be maintained by or under any law for the time

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

ITA/172/2017HC Karnataka25 Sept 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 260

145 ITR 323 (Kar): TC 44R. 1060 distinguished” CASE LAWS RELIED UPON BY THE RESPONDENT – ASSESSEE: 50. 50. Mr. A. Shankar, the learned counsel appearing for the Respondent Assessee who has not Date of Judgment 25-09-2018 I.T.A.No.155/2016 and connected matters The Pr. Commissioner of Income Tax & Ors. Vs. M/s. Chamundi Winery and Distillery 96/137 only painstakingly prepared

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

ITA/467/2015HC Karnataka25 Sept 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 260

145 ITR 323 (Kar): TC 44R. 1060 distinguished” CASE LAWS RELIED UPON BY THE RESPONDENT – ASSESSEE: 50. 50. Mr. A. Shankar, the learned counsel appearing for the Respondent Assessee who has not Date of Judgment 25-09-2018 I.T.A.No.155/2016 and connected matters The Pr. Commissioner of Income Tax & Ors. Vs. M/s. Chamundi Winery and Distillery 96/137 only painstakingly prepared

SMT. M R PRABHAVATHY vs. THE DEPUTY COMMISSIONER OF INCOME TAX

WTA/1/2019HC Karnataka04 Mar 2020

Bench: The Hon’Ble Mr. Justice K.Natarajan Election Petition No.1 Of 2019 Connected With Election Petition No.2 Of 2019

Section 81

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

MR. BINEESH KODIYERI vs. DIRECTORATE OF ENFORCEMENT

WP/13261/2020HC Karnataka16 Mar 2021

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

Section 19Section 482

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

THE PR. COMMISSIONER OF INCOME TAX vs. M/S GOLDMAN SACHS SERVICES PVT LTD

ITA/29/2019HC Karnataka10 Jun 2021

Bench: The Hon'Ble Mr. Justice V. Srishananda Civil Revision Petition No.29/2019 Between

Section 115Section 37(2)

145 flats is to be calculated on the basis of the evidence that is placed before the tribunal. The fact that the sale deeds are registered for a lower price than the agreed price is not a ground to say that the dispute between the parties cannot be arbitrated. That the arbitrator has referred to various judgments

R JANARDHANA BABU vs. THE MANAGING DIRECTOR

Accordingly, the writ petitions are allowed

WP/37528/2010HC Karnataka07 Jul 2017

Bench: The Hon’Ble Mr. Justice B. Veerappa

145. Elizebeth Tarsius, d/o D Devaraj, aged about years, Glaxosmithkline Pharmaceuticals Limited, Devanahalli Road, Off Old Madras Road, Bangalore-560049 146. Lezinda Francis, d/o A J Thomas, aged about 58 years, Glaxosmithkline Pharmaceuticals Limited, Devanahalli Road, Off Old Madras Road, Bangalore-560049 147. Dayamani Dhanpal, d/o Selvaraj, aged about 58 years, Glaxosmithkline Pharmaceuticals Limited, Devanahalli Road, Off Old Madras Road

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

SMT G B RATHNAMMA vs. STATE OF KARNATAKA

WP/51144/2016HC Karnataka27 Sept 2021

Bench: The Hon’Ble Mr. Justice Aravind Kumar W.P. No.51929/2014 C/W W.P.Nos.42063/2012, 30494/2013, 42671/2013, 638/2014, 797/2014, 1089/2014, 3211/2014, 3389/2014, 6180/2014, 10356/2014, 12014/2014, 12015/2014, 13043/2014, 13045/2014, 13206/2014, 13207/2014, 13398/2014, 13774/2014, 14149/2014, 14161/2014, 14494/2014, 14502/2014, 14521/2014, 14689/2014, 16646/2014, 17051/2014, 17594/2014, 19729/2014, 21158/2014, 23897/2014, 28861/2014, 30731/2014, 31723/2014, 33774/2014, 33777/2014, 34084/2014, 34259/2014, 34272/2014, 34391/2014, 35204/2014, 35243/2014, 35247/2014, 35305/2014, 35609/2014, 36164/2014, 36166/2014, 36489/2014, 36525/2014, 36971/2014, 37446/2014, 38055/2014, 38463/2014, 38471/2014, 38472/2014, 38661/2014, 38753/2014, 39383/2014, 39633/2014, 39832/2014, 40204/2014, 40379/2014, 41394/2014, 41422/2014, 41427/2014, 41428/2014, 41858/2014, 43815/2014, 43963/2014, 44306/2014, 44527/2014, 44742/2014, 44835/2014, 45486/2014, 46766/2014, 47103/2014, 47105/2014, 47106/2014, 47107/2014, 47608/2014, 47731/2014, 47821/2014, 47860/2014, 47913/2014, 48577/2014, 48880/2014, 49567/2014, 50260/2014, 50533/2014, 51294/2014, 51930/2014, 51931/2014, 51932/2014, 52760/2014, 53854/2014, 54059/2014, 54083/2014, 54236/2014

SECTION 19(1) OF THE BDA ACT I.E., ANNEX-P, IN SO FAR AS IT RELATES TO THE PROPERTIES OF THE PETITIONER IN SY.NO.30/6 & 30/7, K. NARAYANAPURA VILLAGE, K.R. PURAM HOBLI, BANGALORE SOUTH TALUK, MEASURING 22 GUNTAS AND 26 GUNTAS RESPECTIVELY. IN W.P.NO.55081/2014: BETWEEN: MR N. R. VENKATESHMURTHY S/O SRI. RAMAKRISHNAPPA, AGED ABOUT 45 YEARS, R/AT HOUSE NO.5

SHADRACH vs. THE STATE OF KARNATAKA

WP/53428/2017HC Karnataka27 Sept 2021

Bench: The Hon’Ble Mr. Justice Aravind Kumar W.P. No.51929/2014 C/W W.P.Nos.42063/2012, 30494/2013, 42671/2013, 638/2014, 797/2014, 1089/2014, 3211/2014, 3389/2014, 6180/2014, 10356/2014, 12014/2014, 12015/2014, 13043/2014, 13045/2014, 13206/2014, 13207/2014, 13398/2014, 13774/2014, 14149/2014, 14161/2014, 14494/2014, 14502/2014, 14521/2014, 14689/2014, 16646/2014, 17051/2014, 17594/2014, 19729/2014, 21158/2014, 23897/2014, 28861/2014, 30731/2014, 31723/2014, 33774/2014, 33777/2014, 34084/2014, 34259/2014, 34272/2014, 34391/2014, 35204/2014, 35243/2014, 35247/2014, 35305/2014, 35609/2014, 36164/2014, 36166/2014, 36489/2014, 36525/2014, 36971/2014, 37446/2014, 38055/2014, 38463/2014, 38471/2014, 38472/2014, 38661/2014, 38753/2014, 39383/2014, 39633/2014, 39832/2014, 40204/2014, 40379/2014, 41394/2014, 41422/2014, 41427/2014, 41428/2014, 41858/2014, 43815/2014, 43963/2014, 44306/2014, 44527/2014, 44742/2014, 44835/2014, 45486/2014, 46766/2014, 47103/2014, 47105/2014, 47106/2014, 47107/2014, 47608/2014, 47731/2014, 47821/2014, 47860/2014, 47913/2014, 48577/2014, 48880/2014, 49567/2014, 50260/2014, 50533/2014, 51294/2014, 51930/2014, 51931/2014, 51932/2014, 52760/2014, 53854/2014, 54059/2014, 54083/2014, 54236/2014

SECTION 19(1) OF THE BDA ACT I.E., ANNEX-P, IN SO FAR AS IT RELATES TO THE PROPERTIES OF THE PETITIONER IN SY.NO.30/6 & 30/7, K. NARAYANAPURA VILLAGE, K.R. PURAM HOBLI, BANGALORE SOUTH TALUK, MEASURING 22 GUNTAS AND 26 GUNTAS RESPECTIVELY. IN W.P.NO.55081/2014: BETWEEN: MR N. R. VENKATESHMURTHY S/O SRI. RAMAKRISHNAPPA, AGED ABOUT 45 YEARS, R/AT HOUSE NO.5