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5 results for “transfer pricing”+ Section 40A(7)clear

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Key Topics

Section 26016Section 14A2Disallowance2

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

In the result, the appeals are partly allowed

ITA/133/2007HC Karnataka23 Aug 2013

Bench: B.MANOHAR,DILIP B.BHOSALE

Section 260

Section 40A(9) of the Act? 7 5. In ITA 133/07, the following two substantial questions of law arise for our consideration: A-9. Whether the Tribunal was correct in holding that the stock transfers made to the new industrial undertaking at Amalnar for manufacture of fatty acid and glycerin plant should be taken at market price

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

The appeals stand disposed of, accordingly

ITA/881/2008HC Karnataka25 Mar 2015

Bench: N.KUMAR,B.SREENIVASE GOWDA

Section 260

7. Assessee preferred an appeal before the Commissioner of Income Tax (Appeals) [CIT(A)] which was disposed-off by the CIT(A) vide order dated 20.03.2006. Aggrieved by the said order, both the assessee and the Department preferred separate appeals before the ITAT. The ITAT, vide common order dated 30.05.2008 disposed of the appeals. Assessment Year

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

The appeals stand disposed of, accordingly

ITA/211/2009HC Karnataka25 Mar 2015

Bench: N.KUMAR,B.SREENIVASE GOWDA

Section 260

7. Assessee preferred an appeal before the Commissioner of Income Tax (Appeals) [CIT(A)] which was disposed-off by the CIT(A) vide order dated 20.03.2006. Aggrieved by the said order, both the assessee and the Department preferred separate appeals before the ITAT. The ITAT, vide common order dated 30.05.2008 disposed of the appeals. Assessment Year

THE PR COMMISSIONER OF INCOME TAX vs. ADC INDIA COMMUNICATIONS LTD

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

ITA/494/2022HC Karnataka30 Sept 2024

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

Section 260Section 40Section 40A(7)Section 9(1)(vii)

Transfer Pricing Officer had chosen comparables after satisfying required tests namely, qualitative and quantitative filers and considering their functions and as such the order passed by Tribunal is perverse in nature? 2. Whether on the facts and in the circumstances of the case, the Tribunal’s order can be said as perverse in nature as Tribunal has directed the assessing

PR COMMISSIONER OF INCOME TAX- 4 vs. M/S JUPITER

Appeal is allowed in part accordingly

ITA/297/2017HC Karnataka13 Mar 2023

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

Section 14ASection 260Section 36(1)(ii)Section 37Section 40A(2)

pricing of these shares at a premium of Rs.490/- per share? 2. Whether on the facts and in the circumstances of the case, the Tribunal is right in deleting the disallowance made under Section 14A read with Rule 8D(ii) of the Act by relying upon the decision of Hon'ble Delhi High Court in the case of Cheminvest Limited