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3 results for “transfer pricing”+ Section 194Cclear

Sorted by relevance

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Key Topics

Section 10A6Section 2603Section 194J3Section 194C3Section 260A2Section 322Section 143(3)2TDS2Disallowance2

THE PR. COMMISSIONER OF INCOME TAX vs. M/S APIGEE TECHNOLOGIES

ITA/138/2016HC Karnataka03 Jul 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 194CSection 194cSection 260Section 260ASection 92C

transfer pricing adjustment in accordance with parameters of I.T. Acta and Rules framed there under? 3.Whether on the facts and in the circumstances of the Tribunal is right in allowing the appeal filed by the assessee relating issue of TDS by erroneously holding that payments referred to in the assessment order are outside the purview of section 194C

ASSISTANT COMMISSIONER OF INCOME TAX vs. M/S GULBARGA ELECTRICITY SUPPLY COMPANY LTD.

Accordingly, appeal of Revenue is dismissed

ITA/200003/2014
HC Karnataka
09 Aug 2016

Bench: B.VEERAPPA,VINEET KOTHARI

Section 133ASection 143(3)Section 194CSection 194JSection 201(1)Section 260Section 32Section 40

price fixed by KERC. Assessee was oblivious to the technical expertise which the KPTCL may possess. There was neither transfer of any technology nor any service attributable to a technical service offered by the KPTCL and accepted by the assessee. Therefore, application of Section 194J of the Act to the facts of this case by the Revenue is misconceived.” (emphasis

PR COMMISSIONER OF vs. M/S WIPRO LIMITED

In the result, the appeal is disposed of in terms

ITA/464/2017HC Karnataka09 Dec 2020

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 10ASection 260Section 260ASection 32

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 of the Act directed the Assessing Officer to follow the directions given the claim of the assessee under Section 14A of the Act set aside the finding recorded by the Assessing Officer