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

PR COMMISSIONER OF vs. M/S SOFTBRANDS INDIA

Bench: S.SUJATHA,VINEET KOTHARI

Transfer Pricing Officer (TPO) or Dispute Resolution Panel (DRP) which comprises of three Commissioners and the Revenue or the assessee may feel dissatisfied, because of the reversal or modification of such findings by the Tribunal resulting in leaving out of certain comparables or adding on of certain comparables for determining the ‘Arm’s Length Price’ in the hands

PR COMMISSIONER OF vs. M/S SOFTBRANDS INDIA

Bench: S.SUJATHA,VINEET KOTHARI

Transfer Pricing Officer (TPO) or Dispute Resolution Panel (DRP) which comprises of three Commissioners and the Revenue or the assessee may feel dissatisfied, because of the reversal or modification of such findings by the Tribunal resulting in leaving out of certain comparables or adding on of certain comparables for determining the ‘Arm’s Length Price’ in the hands

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

Bench: S.SUJATHA,VINEET KOTHARI

price of shares of the Assessee - Indian Company, would certainly fall within the ambit of Section 2(22)(e) of the Act and could be taxed as Dividends, in the hands of the Assessee Company. 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. 9/86

SHRI. PARSWANATH vs. ASSISTANT COMMISSIONER OF INCOME TAX

Bench: The Hon'Ble Mr. Justice M. Nagaprasanna

price in buying or selling. [Wharton's Law Lexicon, 1976 Reprint Ed.]. Expression “abatement” has been separately spelt out, in the same dictionary. “Abatement of criminal proceedings” has been termed to mean their termination 26 without a decision on the merits and without the assent of the prosecutor. If this is the legal position or meaning of abatement

HEWLETT PACKARD FINANCIAL SERVICES INDIA PRIVATE vs. THE STATE OF KARNATAKA

Bench: S.SUJATHA,JAYANT PATEL

transferred to the appellant and till then the rights over the goods wrests with the end customer only. In-fact in the MLA as pointed out by the FAA and AA, the description of leased equipments are not forthcoming and the appellant is not aware of the goods to be leased till the purchase order is placed

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

The appeal is dismissed

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

2) of the Act. In view of the international transactions, the Assessing Officer referred the matter to the Transfer Pricing Officer (TPO) for determination of the arm’s length price. The TPO, by order dated 29.01.2016 passed under Section

SRI N GOVINDARAJU vs. THE INCOME TAX OFFICER

Appeal stands disposed of

Bench: S.SUJATHA,VINEET SARAN

price received as a result of the transfer of a capital asset. It is different from ‘fair market value’ of the property, which phrase is used in section 45(2

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:

section (254, 263,264 orders) Post 01.04.2019, If the order is received after 01.04.2019, then in such cases the time limit has been increased to 12 months 153(4) Notwithstandi ng sub-sec, (1), (2) & (3), where a reference has been made to Transfer Pricing

THE COMMISSIONER OF INCOME TAX vs. M/S SHASTHA PHARMA LABORATORIES

The appeal is dismissed

Bench: N.KUMAR,RATHNAKALA

price of Rs.50.12/- lakhs did not amount to a transfer and consequently, no capital gains tax was liable to be paid.?” 7. However, before commencement of the arguments, learned Counsel for the revenue sought the permission of the Court to raise additional substantial question of law : “Whether the Tribunal was correct in holding the reopening of assessment under Sections

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.

Transfer Pricing Officer passed order under Section 92CA on 30.01.2015. Thereafter, the respondent passed draft assessment order under Section 144C read with Section - 4 - HC-KAR NC: 2025:KHC:19558-DB ITA No. 571 of 2017 143(2

M/S J K CEMENT WORKS vs. THE STATE OF KARNATAKA

Bench: H.B.PRABHAKARA SASTRY,VINEET KOTHARI

transfer of property in goods in connection with the execution of works contract, that is claimed as deduction. (d) Notwithstanding anything contained in this Act, where any dealer has sold goods at a price lesser than the price of such goods purchased by him, the amount of input tax credit shall be restricted to the amount of output

THE COMMISSIONER OF INCOME TAX vs. PRAVEEN V DODDANAVAR

Bench: SREENIVAS HARISH KUMAR,VINEET KOTHARI

transfer of property in goods in connection with the execution of works contract, that is claimed as deduction. (d) Notwithstanding anything contained in this Act, where any dealer has sold goods at a price lesser than the price of such goods purchased by him, the amount of input tax credit shall be restricted to the amount of output

THE BAILHONGAL URBAN COOPERATIVE BANK LTD vs. THE COMMISSIONER OF INCOME TAX

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

transfer of property in goods in connection with the execution of works contract, that is claimed as deduction. (d) Notwithstanding anything contained in this Act, where any dealer has sold goods at a price lesser than the price of such goods purchased by him, the amount of input tax credit shall be restricted to the amount of output

PR.COMMISSIONER OF INCOMETAX-2 vs. M/S.EYGBS (INDIA) PVT LTD

Bench: CHIEF JUSTICE,C M JOSHI

Transfer Pricing Officer and to avoid rigors of Section 92C(4) of the Act and consequently enhanced benefits under section 10AA of the Act"? (ii) "Whether on facts and circumstances of the case, the Tribunal's order can be said as perverse in nature in not appreciating that the assesee failed to substantiate an furnish details

PR COMMISSIONER OF vs. M/S LUWA INDIA PRIVATE LIMITED

Bench: ALOK ARADHE,HEMANT CHANDANGOUDAR

Transfer Pricing Officer/Assessing Authority is not right in treating Arms length Price for royalty payment as 'NIL' eventhough the TPO had clearly established that 3 assessee had not derived any benefit out of royalty payment?" 2. Facts leading to filing of this appeal briefly stated are that the assessee filed the return of income for the Assessment Year

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