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6 results for “transfer pricing”+ Section 194Jclear

Sorted by relevance

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Key Topics

Section 26013Section 1928Section 194J7Section 1946Section 201(1)5TDS5Survey u/s 133A4Section 143(3)3Deduction3Section 133

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

Accordingly, appeal of Revenue is dismissed

ITA/200003/2014HC Karnataka09 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

2
Section 133A2
Disallowance2

THE COMMISSIONER OF INCOME TAX vs. HUBLI ELECTRIC SUPPLY COMPANY LTD

In the result, these appeals fail and accordingly stand

ITA/437/2012HC Karnataka15 Dec 2015

Bench: S.ABDUL NAZEER,P.S.DINESH KUMAR

Section 133ASection 194JSection 201Section 201(1)Section 260

price fixed by KERC. Assessee was oblivious to the technical expertise which the KPTCL may possess. There was neither transfer of any : 15 : technology nor any service attributable to a technical service offered by the KPTCL and accepted by the assessee. Therefore, application of Section 194J

M/S SUBEX LTD vs. THE DEPUTY COMMISSIONER

Appeal is allowed

ITA/787/2017HC Karnataka22 Dec 2022

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

Section 10Section 143(3)Section 260Section 92

Transfer Pricing Officer 4 Dispute Resolution Panel I.T.A No.787/2017 4 the ITAT. The ITAT upheld the relief granted by DRP except the year-end provisions made towards legal and professional charges. In this appeal, we are concerned with the disallowance of the provision for legal and professional charges. 4. Shri. K.K. Chaithanya, learned Senior Advocate for the assessee submitted that

THE COMMISSIONER OF INCOME TAX vs. M/S URBAN LADDER HOME DECOR SOLUTIONS PVT LTD

Appeals are dismissed

ITA/11/2022HC Karnataka07 Feb 2025

Bench: V KAMESWAR RAO,S RACHAIAH

Section 260

price fixed. However, in the facts of present case, looking at the documentation, the billing is segregated into various services i.e. AWS services, storage services, etc. and the assessee before us has filed a chart of summary of services availed. The first such services are on account of service charges for Elastic Compute Cloud. As per clause

THE COMMISSIONER OF INCOME TAX vs. M/S MANIPAL HEALTH SYSTEMS

Appeals are partly allowed to the extent indicated

ITA/746/2009HC Karnataka09 Mar 2015

Bench: S.SUJATHA,VINEET SARAN

Section 133Section 192Section 194Section 194JSection 201(1)Section 260

194J of the Act? 2. Whether the Appellate Authorities were correct in holding that the lease rent paid to Medical Relief Society of South Canara under the guise of repayment of loan taken by the lessor under a supplementary agreement would not attract section 194-I of the Act and tax at source need not be deducted when the said

THE COMMISSIONER OF INCOME TAX vs. M/S MANIPAL HEALTH SYSTEMS PVT LTD

Appeals are partly allowed to the extent indicated

ITA/747/2009HC Karnataka09 Mar 2015

Bench: S.SUJATHA,VINEET SARAN

Section 133Section 192Section 194Section 194JSection 201(1)Section 260

194J of the Act? 2. Whether the Appellate Authorities were correct in holding that the lease rent paid to Medical Relief Society of South Canara under the guise of repayment of loan taken by the lessor under a supplementary agreement would not attract section 194-I of the Act and tax at source need not be deducted when the said