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

transfer pricing Rs.20,20,07,861/-, disallowance under Section 14A read with Rule 8D(2)(iii) to the extent of Rs.20

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

In the result, we don to find any

Bench: ALOK ARADHE,R. NATARAJ

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 PR COMMISSIONER OF INCOME TAX, CIT(A) vs. M/S DELHI INTERNATIONAL AIRPORT PVT LTD

In the result, we don to find any

Bench: SATISH CHANDRA SHARMA,R. NATARAJ

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

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:

Transfer Pricing Officer during the proceeding for assessment, reassessment made. The period as specified in sub- section (1)(2) & (3) shall be further extended by 12 months. 153(5) To give effect to the order of the higher authorities i.e. CIT (A), ITAT, HC and SC orders To give effect to an order passed by higher authorities other than those

M/S. EVERGREEN HARDWARE STORES vs. THE ASSISTANT COMMISSIONER OF

Appeal is allowed

Bench: P.S.DINESH KUMAR,UMESH M ADIGA

14A read with Rule 8D of the Rules is not sustainable. I.T.A No.201/2017 8 8. Re:Addition under Section 45(4) in respect of: (a) land at Adugodi Rs.54,89,677/- (b) Building Rs.68,86,826; Shri. Shankar submitted that a plot was purchased by one of the partners Shri. Mannon M. Aeranpurwala in the year 1994. The same

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

Bench: ARAVIND KUMAR,SURAJ GOVINDARAJ

transfer pricing order under Section 92CA of the Act to determine arms length price as the assessee had entered into specified domestic transaction and on the 4 ground it was covered under Section 92BA of the Act. Despite objections being filed by the assessee before Dispute Resolution Panel (for short ‘DRP’) directions came to be issued

PR. COMMISSIONER OF INCOME TAX-2 vs. M/S TT STEEL SERVICE INDIA PVT LTD

Bench: V KAMESWAR RAO,S RACHAIAH

Transfer Pricing Adjustment to International Transaction with Associated Enterprises only even when same is contrary to Section 92CA of the Act and when assesse is providing service to both AE and Non-AE's where assesse has not made any bifurcation of profit in book of account as overall profit margin is recorded in books without any data

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

The appeal is dismissed

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

14A) The provisions of this section shall not apply to any assessment or reassessment order passed by the Assessing Officer with the prior approval of the [Principal Commissioner or] Commissioner as provided in sub-section (12) of section 144BA.] (14B) The Central Government may make a scheme, by notification in the Official Gazette, for the purposes of issuance of directions

PR COMMISSIONER OF vs. M/S WIPRO LIMITED

In the result, the appeal is disposed of in terms

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Transfer Pricing Officer (TPO) to follow the directions given by the tribunal in earlier Assessment Year. The tribunal with regard to claim of assessee under Section 14A

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

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

M/S CANARA BANK BSCA SECTION vs. THE ASST COMMISSIONER OF INCOME TAX CIRCLE-11(2)

Bench: N.KUMAR,RATHNAKALA

14A of the Act to 2% of - 7 - the gross receipts on account of dividends and interest which are exempt following earlier order of his own in the assessee’s case for the assessment year 1998-99. The said order was challenged before the Tribunal. The Tribunal confirmed the said order, in view of the fact that for the earlier

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

The appeal is dismissed

Bench: B.V.NAGARATHNA,JAYANT PATEL

14A as per Rule 8D? 2. We have heard Mr. Aravind, learned counsel appearing for the appellant - Revenue. 3. On the first question, the observations made by the Tribunal in the impugned order from paragraph Nos.12 to 17 are as under: “12. We have heard the submissions of the ld. DR and the ld. counsel for the assessee and also

PR COMMISSIONER OF INCOME TAX- 4 vs. M/S JUPITER

Appeal is allowed in part accordingly

Bench: P.S.DINESH KUMAR,C.M. POONACHA

pricing of these shares at a premium of Rs.490/- per share? 2. Whether on the facts and in the circumstances of the case, the Tribunal is right in deleting the disallowance made under Section 14A read with Rule 8D(ii) of the Act by relying upon the decision of Hon'ble Delhi High Court in the case of Cheminvest Limited

KARNATAKA STATE BEVERAGES CORPORTION LIMITED vs. THE COMMISSIONER OF INCOME TAX

Bench: The Hon’Ble Mr. Justice Anand Byrareddy Writ Petition No.12872 Of 2013 (T-It) Connected With Writ Petition No.14687 Of 2014 (T-It), Writ Petition No.15910 Of 2015 (T-It) & Writ Petition No.17514 Of 2015 (T-It) In W.P.No.12872 Of 2013 Between: Karnataka State Beverages Corporation Limited, Represented By It’S Executive Director (Finance), Sri. Shrikant B Vanahalli, Aged About 57 Years, No.78, Seethalakshmi Towers, Mission Road, Bangalore 560 027. …Petitioner

14A of the Act in a sum of Rs.19,20,039/-, disallowance of provision for ex-gratia Rs.37,52,700/- and disallowance of expenditure on increase in share capital Rs.4,85,000/-, by order dated 26.02.2014. Similarly, an assessment order was passed under Section 143(3) of the Act for the assessment year 2012-13 wherein the Assessing Officer