PR COMMISSIONER OF vs. M/S SOFTBRANDS INDIA

Bench: S.SUJATHA,VINEET KOTHARI

Transfer Date of Judgment 25-06-2018 I.T.A.No.536/2015 C/w I.T.A.No.537/2015 Pr. Commissioner of Income Tax & Anr. Vs. M/s. Softbrands India P. Ltd., 51/80 Pricing cases of International Taxation under these provisions in income arising from international transactions which shall be computed having regard to the ‘Arm’s Length Price’ (Sec.92). 33. Section 92-A defines an ‘Associate Enterprise

PR COMMISSIONER OF vs. M/S SOFTBRANDS INDIA

Bench: S.SUJATHA,VINEET KOTHARI

Transfer Date of Judgment 25-06-2018 I.T.A.No.536/2015 C/w I.T.A.No.537/2015 Pr. Commissioner of Income Tax & Anr. Vs. M/s. Softbrands India P. Ltd., 51/80 Pricing cases of International Taxation under these provisions in income arising from international transactions which shall be computed having regard to the ‘Arm’s Length Price’ (Sec.92). 33. Section 92-A defines an ‘Associate Enterprise

THE COMMISSIONER OF INCOME TAX vs. M/S KARNATAKA CO-OPERATIVE MILK PRODUCERS

Appeal is dismissed with costs

Bench: The Hon’Ble Mr. Justice N.K.Sudhindrarao R.S.A.No.70/2007

34, the following section insert:— “34A. Person claiming under document for sale of property also to sign document.—Subject to the provisions of this Act, no document for sale of peoperty shall be registered under this Act, unless the person claiming under the document has also signed such document.”. [Vide Tamil Nadu Act 28 of 2000]. 35. Procedure on admission

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

34,08,185/-. The assessee later on filed a revised return on 30.03.2011. The assessee had international transactions with its associate enterprises. Therefore, the Assessing Officer referred the case of the assessee to the Transfer Pricing Officer to determine the Arms Length price. 3. The Transfer Pricing Officer, after examining the details furnished by the assessee, passed an order under

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

Bench: CHIEF JUSTICE,C M JOSHI

transfer of profits. 29. Thus, indisputably, the income computed on the basis of ALP would provide a measure of the profits or income derived by the - 21 - HC-KAR NC: 2025:KHC:36360-DB ITA No. 107 of 2025 C/W ITA No. 106 of 2025 activities carried on by an Assessee. The proviso to Section 92C(4) essentially limits exemption

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 244A(1A) of the Act has styled the operative portion of the impugned order as under: “In this case, the Hon’ble ITAT, Bengaluru has remitted back the issue of Transfer Pricing to the AO for fresh assessment/re-assessment as per Para No. 5 & 6 of the ITAT order. Further, fresh approval has been taken from

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

Bench: V KAMESWAR RAO,S RACHAIAH

34, BIDADI INDUSTRIAL AREA RAMANAGARA TALUK BENGALURU - 562 109. …RESPONDENT (BY SRI. T SURYANARAYANA, SR. ADVOCATE FOR SMT. TANMAYEE RAJKUMAR, ADVOCATE) THIS ITA FILED UNDER SEC.260-A OF THE INCOME TAX ACT 1961, PRAYING TO SET ASIDE THE APPELLATE ORDER DATED 06/04/2023 PASSED BY THE INCOME TAX APPELLATE TRIBUNAL, 'B' BENCH, BANGALORE, AS SOUGHT FOR, IN THE RESPONDENT - ASSESSEE'S CASE

PR. COMMISSIONER OF INCOME TAX-2 vs. TOYOTA TSUSHO INDIA PRIVATE LIMITED

Bench: CHIEF JUSTICE,C M JOSHI

34 BIDADI INDUSTRIAL AREA RAMANAGARA DISTRICT BENGALURU - 562 109 PAN: AADCS6230 N …RESPONDENT Digitally signed by SRIDEVI S Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:34395-DB ITA No. 149 of 2025 THIS ITA IS FILED UNDER SECTION 260-A OF THE INCOME TAX ACT, 1961, PRAYING TO DECIDE THE FOREGOING QUESTION

COMMISSIONER OF INCOME TAX vs. SRI.M.R.JANAKIRAM (HUF)

The appeal is allowed

Bench: ARAVIND KUMAR,E.S.INDIRESH

price of the said land and buy the scheduled property situated in 6.3 acres, immediately. 19. Prayer was sought for a direction to the Official Liquidator to sell the said 6.3 acres of schedule property wherein the Institution of the KIAMS is situated by accepting the amount stated therein. 20. Company Court vide order dated 30.09.2008 took note

G RAMACHAR vs. THE STATE OF KARNATAKA

Bench: ABHAY SHREENIWAS OKA (CJ),B.V.NAGARATHNA

34 and 45-A of Karnataka Stamps Act 1957; read with Rule-3 of Karnataka Stamps (prevention of devaluation of documents) Rules, 1977 (to enter the correct market price of the said property); -: 13 :- 3) Section-131(C) of Karnataka Land Revenue Act, 1964; read with Rule-46(H) of Karnataka Land Revenue Rules, (to issue survey sketch or land

COMMISSIONER OF INCOME TAX-III vs. M/S YODLEE INFOTECH PVT LTD

The appeal is disposed of

Bench: ALOK ARADHE,M.I.ARUN

Section 92CA(1) of the Act was made to Transfer Pricing Officer on 14.05.2011 in respect of international transactions viz., Provision of Software Development Services and Marketing and Sales Support Services. The Transfer Pricing Officer by an order dated 31.10.2011 made an upward adjustment of Rs.3,44,14,532/- to the international transactions of the assessee wherein Arm’s Length

COMMISSIONER OF INCOME-TAX vs. M.R.SAMPANGIRAMAIAH

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

price component is already paid and what remains to be paid is Rs.49,80,000/-. Vouchsafing the title to property is a predominant obligation of the vendor, vide condition Nos.6, 7 & 8 in Ex.P4, is not disputed before us. Paragraph 2 stipulates that the plaintiff has to pay this amount in two installments: First installment of Rs.34

PR COMMISSIONER OF vs. M/S ZYME SOLUTIONS P LTD

Bench: S.SUJATHA,VINEET KOTHARI

SECTION 260-A OF INCOME TAX ACT 1961, PRAYING TO 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, AND SET ASIDE THE APPELLATE ORDER DATED 22/01/2016 PASSED BY THE ITAT, ‘B’ BENCH, BENGALURU, AS SOUGHT FOR, IN THE RESPONDENT-ASSESSEE’S CASE, IN Date

M/S SREE JAYALAKSHMI TEXTILES vs. M/S INTERNATIONAL ASSET RECONSTRUCTION

Bench: The Date Fixed For Sale Of Transfer & In Such Event The Secured Asset Shall Not Be Sold & That Once The Auction Sale Process Is Commenced & The Property Is Auctioned & Sold On The Date Fixed For Sale & The Sale In Favour Of The Highest Bidder Is Confirmed & 25%

Section 13(8) read along with Rules 8(6) and 9(1), the owner/borrower should have clear notice of 30 days before the date and time when the sale or transfer of the secured asset would be made, as that alone would enable the owner/borrower to take all efforts to retain his or her ownership by tendering the dues

M/S SREE JAYALAKSHMI TEXTILES vs. M/S INTERNATIONAL ASSET RECONSTRUCTION

Bench: The Date Fixed For Sale Of Transfer & In Such Event The Secured Asset Shall Not Be Sold & That Once The Auction Sale Process Is Commenced & The Property Is Auctioned & Sold On The Date Fixed For Sale & The Sale In Favour Of The Highest Bidder Is Confirmed & 25%

Section 13(8) read along with Rules 8(6) and 9(1), the owner/borrower should have clear notice of 30 days before the date and time when the sale or transfer of the secured asset would be made, as that alone would enable the owner/borrower to take all efforts to retain his or her ownership by tendering the dues

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

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

34,08,342/- The assessee-company also had international transactions with Associated Enterprises, which were referred to the 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

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

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

34,08,342/- The assessee-company also had international transactions with Associated Enterprises, which were referred to the 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

THE PR. COMMISSIONER OF INCOME TAX vs. M/S GOLDMAN SACHS SERVICES PVT LTD

Bench: The Hon'Ble Mr. Justice V. Srishananda Civil Revision Petition No.29/2019 Between

Section 37(2) of the Arbitration and Conciliation Act, 1996. 21. Learned Judge in the First Appellate Court issued the notice of the appeal and after permitting the legal representatives of the first respondent to come on record, noting the death of first respondent, heard the arguments of the revision petitioner alone, as first respondent failed to file objections