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

M/S. HINDUSTAN COCA COLA vs. STATE OF KARNATAKA

Of the Department's clouded interpretation of the Centum

Bench: ANAND BYRAREDDY

price of goods sold to the end consumer. The 24 object of the Act is achieved by allowing dealers to deduct the input tax paid by him on purchases from their output tax liability on sales effected by them, thereby ensuring that tax is levied only on the incremental monetary value addition on each sale of goods. Section

M/S INDIA MOTOR PARTS & ACCESSORIES LTD vs. THE DEPUTY COMMISSIONER OF

Of the Department's clouded interpretation of the Centum

Bench: ANAND BYRAREDDY

price of goods sold to the end consumer. The 24 object of the Act is achieved by allowing dealers to deduct the input tax paid by him on purchases from their output tax liability on sales effected by them, thereby ensuring that tax is levied only on the incremental monetary value addition on each sale of goods. Section

ACE DESIGNERS LIMITED vs. THE STATE OF KARNATAKA

Of the Department's clouded interpretation of the Centum

Bench: ANAND BYRAREDDY

price of goods sold to the end consumer. The 24 object of the Act is achieved by allowing dealers to deduct the input tax paid by him on purchases from their output tax liability on sales effected by them, thereby ensuring that tax is levied only on the incremental monetary value addition on each sale of goods. Section

DEPA INDIA PRIVATE LTD. vs. THE STATE OF KARNATAKA

Of the Department's clouded interpretation of the Centum

Bench: ANAND BYRAREDDY

price of goods sold to the end consumer. The 24 object of the Act is achieved by allowing dealers to deduct the input tax paid by him on purchases from their output tax liability on sales effected by them, thereby ensuring that tax is levied only on the incremental monetary value addition on each sale of goods. Section

INGRAM MICRO INDIA PVT. LTD. vs. THE STATE OF KARNATAKA

Of the Department's clouded interpretation of the Centum

Bench: ANAND BYRAREDDY

price of goods sold to the end consumer. The 24 object of the Act is achieved by allowing dealers to deduct the input tax paid by him on purchases from their output tax liability on sales effected by them, thereby ensuring that tax is levied only on the incremental monetary value addition on each sale of goods. Section

KAVERI PLASTO CONTAINERS PVT LTD vs. THE STATE OF KARNATAKA

Of the Department's clouded interpretation of the Centum

Bench: ANAND BYRAREDDY

price of goods sold to the end consumer. The 24 object of the Act is achieved by allowing dealers to deduct the input tax paid by him on purchases from their output tax liability on sales effected by them, thereby ensuring that tax is levied only on the incremental monetary value addition on each sale of goods. Section

SONAL APPAREL PRIVATE LTD., vs. THE STATE OF KARNATAKA

Of the Department's clouded interpretation of the Centum

Bench: ANAND BYRAREDDY

price of goods sold to the end consumer. The 24 object of the Act is achieved by allowing dealers to deduct the input tax paid by him on purchases from their output tax liability on sales effected by them, thereby ensuring that tax is levied only on the incremental monetary value addition on each sale of goods. Section

INGRAM MICRO INDIA PVT.LTD. vs. THE STATE OF KARNATAKA

Of the Department's clouded interpretation of the Centum

Bench: ANAND BYRAREDDY

price of goods sold to the end consumer. The 24 object of the Act is achieved by allowing dealers to deduct the input tax paid by him on purchases from their output tax liability on sales effected by them, thereby ensuring that tax is levied only on the incremental monetary value addition on each sale of goods. Section

M/S. HINDUSTAN COCA COLA vs. STATE OF KARNATAKA

Of the Department's clouded interpretation of the Centum

Bench: ANAND BYRAREDDY

price of goods sold to the end consumer. The 24 object of the Act is achieved by allowing dealers to deduct the input tax paid by him on purchases from their output tax liability on sales effected by them, thereby ensuring that tax is levied only on the incremental monetary value addition on each sale of goods. Section

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

Transfer Pricing Officer in his under section 92CA dated 29/10/2018 has not considered companies in the final set of comparables"? 3. Learned counsel for the assessee submits that the tax effect in this appeal is less than Rs.2 Crores and therefore, the appeal should not be entertained at the instance of the revenue in view of the Circular No.09/2024 dated

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:

Transfer Pricing Officer during the proceeding for assessment, reassessment made. The period as specified in sub- section (1)(2) & (3) shall be further extended by 12 months. 153(5) To give effect to the order of the higher authorities i.e. CIT (A), ITAT, HC and SC orders To give effect to an order passed by higher authorities other than those

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

Section 100 CPC is directed against the common judgment and decree dated 7-10-2006 passed in R.A.Nos.33 and 35 of 2002 by the District and Sessions Judge and Presiding Officer, Fast Track Court –II, Bangalore Rural District, Bangalore, wherein appeal filed by the plaintiff -K.T. Plantations Private Limited in RA 3 No.33/2002 came to be allowed

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

M/S AMD FAR EAST LTD., vs. THE JOINT DIRECTOR OF INCOME-TAX

Bench: S.SUJATHA,RAVI V HOSMANI

Transfer Pricing Officer wherein Rs.1,35,12,070/- expenditure towards expatriate costs was subjected to tax cannot deny the deductions allowable under Section

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