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:

260 or section 262 or section 264.
The said sections deal with giving effect to orders passed under the sections mentioned therein, either wholly or partly.
The said sections make exception to making of fresh assessment or reassessment.
Section 244A(1A) provides for interest for the period beginning from the date following the date of expiry of the time allowed

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

Bench: ALOK ARADHE,HEMANT CHANDANGOUDAR

Section 260-A of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’, for short) has been filed by the revenue. The subject matter of the appeal pertains to the Assessment Year 2007-08. The appeal was admitted by a Bench of this Court on the following substantial question of law: "Whether on the facts

THE PR. COMMISSIONER OF INCOME TAX CIT(A) vs. M/S IDS SOFTWARE SOLUTIONS INDIA PVT LTD

Bench: ABHAY SHREENIWAS OKA (CJ),S.G.PANDIT

transfer pricing documents and proceeded to determine the arms length price of the international transactions of the assessee on the basis of the material available on record. The assessee raised objection before the Dispute Resolution Panel (for short ‘the DRP’) on the finding of the TPO. On consideration of the objections of the assessee, the DRP directed the Assessing Officer

M/S WIPRO LIMITED vs. THE DEPUTY COMMISSIONER OF INCOME TAX

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

260-A of I.T.Act, 1961 arising out of order dated 30.01.2009 passed in ITA No.1072/BNG/2007, for the assessment year 2004-2005, praying to I) Formulate the substantial questions of law stated therein, II) Allow the appeal and set aside the order passed by the ITAT Bangalore in ITA No.1072/BNG/2007, dated 30-01-2009 confirming the order of the Appellate Commissioner

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

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

260-A of I.T.Act, 1961 arising out of order dated 30.01.2009 passed in ITA No.1072/BNG/2007, for the assessment year 2004-2005, praying to I) Formulate the substantial questions of law stated therein, II) Allow the appeal and set aside the order passed by the ITAT Bangalore in ITA No.1072/BNG/2007, dated 30-01-2009 confirming the order of the Appellate Commissioner

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

260-A of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’, for short) has been filed by the revenue. The subject matter of the appeal pertains to the Assessment Year 2010-11. The appeal was admitted by a Bench of this Court vide order dated 09.11.2018 on the following substantial question of law: "Whether on the facts

THE COMMISSIONER OF INCOME TAX vs. M/S GENISYS INTERGRATING SYSTEMS

Bench: S.SUJATHA,VINEET KOTHARI

Transfer of Shares in Tax Havens (like in the case of Vodafone etc.), if based on relevant facts, such substantial questions of law could be raised before the High Court under Section 260-A of the Act, the Courts could have embarked upon such exercise of framing and answering such substantial question of law. On the other hand, the appeals

PRINCIPAL COMMISSIONER OF INCOME TAX - 6 vs. M/S. SAMSUNG R & D INSTITUTE BANGALORE PVT LTD

In the result, we do not find any merit in this

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

260-A OF I.T. ACT, 1961 ARISING OUT OF ORDER DATED 03.03.2017 PASSED IN 2 IT(TP)A NO.60/BANG/2015 FOR THE ASSESSMENT YEAR 2009-10, VIDE ANNEXURE-A, PRAYING TO: (I) DECIDE THE FOREGOING QUESTION OF LAW AND/OR SUCH OTHER QUESTIONS OF LAW MAY BE FORMULTED BY THE HON'BLE COURT AS DEEMD FIT. (II) SET ASIDE THE APPELLATE ORDER

THE COMMISSIONER OF INCOME TAX vs. M/S FIRST ADVANTAGE OFFSHORE SERVICES PVT LTD

Bench: S.SUJATHA,VINEET KOTHARI

Transfer of Shares in Tax Havens (like in the case of Vodafone etc.), if based on relevant facts, such substantial questions of law could be raised before the High Court under Section 260-A of the Act, the Courts could have embarked upon such exercise of framing and answering such substantial question of law. On Date of Judgment

THE PR COMMISSIONER OF INCOME TAX vs. M/S ARISTA NETWORKS INDIA PVT LTD

The appeal is disposed of with liberty as prayed for by the learned

Bench: S.G.PANDIT,C.M. POONACHA

Section 260-A of the Income Tax Act, 1961 (for short, ‘the Act’) questioning the correctness and legality of order dated 5.10.2021 passed by the Income Tax Appellate Tribunal, ‘B’ Bench, Bengaluru (for short, ‘Appellate Authority’) in IT(TP)A.No.2440/Bang/2019 for the assessment year 2015- 16, raising the following substantial questions

PR. COMMISSIONER OF INCOME TAX-4 vs. M/S. KSHEMA TECHNOLOGIES LIMITED

Bench: S.SUJATHA,VINEET KOTHARI

Transfer of Shares in Tax Havens (like in the case of Vodafone etc.), if based on relevant facts, such substantial questions of law could be raised before the High Court under Section 260-A of the Act, the Courts could have embarked upon such exercise of framing and answering such substantial question of law. On the other hand, the appeals

PR COMMISSIONER OF INCOME TAX-5 vs. M/S NOVELL SOFTWARE DEVELOPMENT (INDIA) PVT.LTD.

In the result, we do not find any merit in this appeal

Bench: ALOK ARADHE,R. NATARAJ

260-A OF INCOME TAX ACT 1961, ARISING OUT OF ORDER DATED 30.09.2016 PASSED IN IT(TP)A NO.281/BANG/2015 FOR THE ASSESSMENT YEAR 2010-11, VIDE ANNEXURE-A, PRAYING TO: 2 (i) DECIDE THE FOREGOING QUESTION OF LAW AND/OR SUCH OTHER QUESTIONS OF LAW AS MAY BE FORMULATED BY THE HON'BLE COURT AS DEEMED FIT. (ii) SET ASIDE

THE PR COMMISSIONER OF INCOME TAX vs. M/S SWISS RE GLOBAL BUSINESS SOLUTIONS INDIA PVT LTD

The appeal is disposed of with liberty as prayed for by the learned

Bench: S.G.PANDIT,C.M. POONACHA

Section 260-A of the Income Tax Act, 1961 (for short ‘the Act’) questioning the correctness and legality of order dated 30.12.2021 passed by the Income Tax Appellate Tribunal 'A' Bench, Bengaluru (for short ‘Appellate Authority’) in IT(TP)A.No.290/Bang/2015 for the assessment year 2010-11, raising the following substantial questions of law: 1. "Whether on the facts

PR. COMMISSIONER OF INCOME TAX-5 vs. M/S ORIGAMI CELLULO PVT LTD

Bench: B M SHYAM PRASAD,T.M.NADAF

260-A OF THE INCOME TAX ACT, 1961 ARISING OUT OF ORDER DATED 15/09/2021 PASSED IN ITA NO.394/BANG/2020, FOR THE ASSESSMENT YEAR 2015-2016. PRAYING THAT THIS HONBLE COURT MAY BE PLEASED TO (1) DECIDE THE FOREGOING QUESTION OF LAW AND / OR SUCH OTHER QUESTIONS OF LAW AS MAY BE FORMULATED BY THE HONBLE COURT AS DEEMED

THE PR COMMISSIONER OF INCOME TAX vs. M/S ACUSIS SOFTWARE INDIA

Bench: S.SUJATHA,VINEET KOTHARI

Transfer of Shares in Tax Havens (like in the case of Vodafone etc.), if based on relevant facts, such substantial questions of law could be raised before the High Court under Section 260-A of the Act, the Courts could have embarked upon such exercise of framing and answering such substantial question of law. On the other hand, the appeals

COMMISSIONER OF INCOME TAX vs. TNT INDIA PRIVATE LIMITED

Bench: S.SUJATHA,VINEET KOTHARI

transfer price. For this preposition, learned counsel for the assessee drew our attention to sec.92C(2) of the IT Act, wherein it is provided that where more than one price is arrived at by the most appropriate method the arm’s length price shall be taken to be the arithmetical mean of such prices, or at the option

THE PR. COMMISSIONER OF INCOME TAX vs. M/S EDS ELECTRONICS DATA SYSTEMS INDIA PVT.LTD.

In the result, we do not find any merit in this

Bench: ALOK ARADHE,R. NATARAJ

260-A OF INCOME TAX ACT 1961, ARISING OUT OF ORDER DATED 23.06.2015 PASSED IN ITA NO.1050/DEL/2009 FOR THE ASSESSMENT YEAR 2004-05, PRAYING TO DECIDE THE FOREGOING QUESTION OF LAW AND/OR 2 SUCH OTHER QUESTIONS OF LAW AS MAY BE FORMULATED BY THE HON'BLE COURT AS DEEMED FIT. SET ASIDE THE APPELLATE ORDER DATED 23.06.2015 PASSED

COMMISSIONER OF INCOME TAX-III, vs. M/S SAP LABS INDIA PVT LTD

Bench: S.SUJATHA,VINEET KOTHARI

Transfer of Shares in Tax Havens (like in the case of Vodafone etc.), if based on relevant facts, such substantial questions of law could be raised before the High Court under Section 260-A of the Act, the Courts could have embarked upon such exercise of framing and answering such substantial question of law. On the other hand, the appeals