THE PRINCIPAL COMMISSIONER vs. M/S OBULAPURAM MINING

Bench: K.SOMASHEKAR,UMESH M ADIGA

6 only because one of the directors of the assessee company and of GLATIPL is common, Section 93CA is not applicable. The Tribunal also held that in order to constitute a relationship of an AE, the parameters laid down in both subsections (1) and (2) should be fulfilled. As per explanation, amendment carried out in sub-section (2) of section

M/S PADMINI PRODUCTS (P) LTD., vs. THE DEPUTY COMMISSIONER OF INCOME TAX

In the result, the aforesaid

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

6) of section 43. Explanation 3.—For the purposes of this sub-section, the expression "assets" shall mean— (a) tangible assets, being buildings, machinery, plant or furniture; 14 (b) intangible assets, being know-how, patents, copyrights, trade marks, licences, franchises or any other business or commercial rights of similar nature. Explanation 3- Where, before the date of acquisition

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

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.

43 YEARS, D/O SHRI. DAYANANDA ULLAL) PAN:AADFT 3025 B. …APPELLANT (BY SRI. K.K. CHYTHANYA, SR. COUNSEL FOR SRI TATA KRISHNA, ADV.) AND: THE DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(1) BMTC BUILDING, 80FT. ROAD, KORAMANGALA 6TH BLOCK, BENGALURU-560 095. …RESPONDENT (BY SRI. Y.V. RAVIRAJ, ADV. FOR) THE ADVOCATE FOR THE APPELLANT HAS FILED THE ABOVE

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

43 of the order refers to the fact of realization of the amount by the sale of 145 flats. The amount realized by sale of 145 flats is to be calculated on the basis of the evidence that is placed before the tribunal. The fact that the sale deeds are registered for a lower price than the agreed price

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

Bench: CHIEF JUSTICE,C M JOSHI

transfer pricing [TP] adjustments of ₹14,82,00,000/-, which was reworked at ₹21,36,91,000/- on - 6 - HC-KAR NC: 2025:KHC:36360-DB ITA No. 107 of 2025 C/W ITA No. 106 of 2025 account of APA. Similarly, the Assessee had along with his return, made TP adjustments

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

Section 143(3) of the Act assessed the income at Rs.33,98,72,603/- after making disallowances with regard to addition on account of income from other sources, addition on account of foreign exchange loss and addition on account of Arms 6 Length Price (ALP). 5. The assessee thereupon filed an appeal before the Commissioner of Income Tax (Appeals

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

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

43, 45, 69, 75, 77, 88 and 89, no document shall be registered under this Act, unless the persons 64 executing such document, or their representatives, assigns or agents authorized as aforesaid, appear before the registering officer within the time allowed for presentation under sections 23, 24, 25 and 26: Provided that, if owing to urgent necessity or unavoidable accident

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

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

THE PR COMMISSIONER OF INCOME TAX vs. M/S ACI WORLDWIDE SOLUTIONS PVT LTD

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

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 12.10.2020 passed by the Income Tax Appellate Tribunal, ‘A’ Bench, Bengaluru (for short, ‘Appellate Authority’) in IT(TP)A.Nos.160 and 211/Bang/2016 for the assessment year 2011-12, raising the following substantial questions of law: “1. Whether

THE PR COMMISSIONER OF INCOME TAX-1 vs. ROBERT BOSCH ENGINEERING AND BUSINESS SOLUTIONS PVT LTD

Appeal of the revenue is hereby dismissed

Bench: CHIEF JUSTICE,C M JOSHI

Section 92CA making an transfer pricing adjustment. The learned TPO inter alia adopted the following filter for selection of comparables for the purpose of transfer pricing analysis.
“Companies whose SWD / IT enabled Service is less than 75% of the total operating revenues were excluded The companies whose revenues from software development and related services are more than 75% of their

THE COMMISSIONER OF INCOME TAX vs. M/S QUEST GLOBAL ENGINEERING SERVICES PVT. LTD.,

In the result, we don to find any

Bench: ALOK ARADHE,R. NATARAJ

6. It is also contended that featured sales are obviously uncertain and action of the assessee in so far as hedging 8 anything such as future sales through forward contract is purely speculative transaction and since the loss has not arisen in the course of sale and also not on account of the reinstatement of assets and liabilities based

THE PR. COMMISSIONER OF INCOME TAX vs. M/S CISCO SYSTEMS

The appeals are allowed; the impugned

Bench: SATISH CHANDRA SHARMA,R. NATARAJ

6) of section 43. Explanation 3.—For the purposes of this sub- section, the expression "assets" shall mean— (a) tangible assets, being buildings, machinery, plant or furniture; (b) intangible assets, being know-how, patents, copyrights, trade marks, licences, franchises or any other business or commercial rights of similar nature. Explanation 4.—For the purposes of this sub- section, the expression

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