PR COMMISSIONER OF vs. M/S SOFTBRANDS 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 Date of Judgment 25-06-2018 I.T.A.No.536/2015 C/w I.T.A.No.537/2015 Pr. Commissioner of Income

PR COMMISSIONER OF vs. M/S SOFTBRANDS 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 Date of Judgment 25-06-2018 I.T.A.No.536/2015 C/w I.T.A.No.537/2015 Pr. Commissioner of Income

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

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

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

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

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

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

Bench: CHIEF JUSTICE,C M JOSHI

transfer pricing adjustment at `25,23,76,521/- in the trading segment. 6. In so far as manufacturing segment is concerned, the learned TPO determined the arms length PLI at 3.45% and accordingly made in adjustment of `6,02,89,351/- for the manufacturing segment

THE COMMISSIONER OF INCOME-TAX vs. M/S. CURAM SOFTWARE INTERNATIONAL

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

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

price for sale of property sold by her husband which is western portion of Tataguni estate in favour of plaintiff-Company and she has not agreed to sell the plaint schedule property to the plaintiff at the rate of Rs.40,000/- per acre. 17. It is further claimed that Managing Director of plaintiff-Company K.T. Bhagath was with

THE COMMISSIONER OF INCOME TAX vs. M/S 24/7 CUSTOMER .COM 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

COMMISSIONER OF INCOME TAX vs. TNT INDIA PRIVATE 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

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

THE COMMISSIONER OF INCOME-TAX vs. DR. PRADEEP KUMAR

Bench: RAVI MALIMATH,N.KUMAR

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. M.R.SAMPANGIRAMAIAH

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

56 YEARS, R/AT NO.659, 5TH CROSS, 3RD BLOCK, KORAMANGALA, BANGALORE-560 034. …RESPONDENTS (BY SRI. S S NAGANAND., SENIOR COUNSEL A/W SRI. VIJAYKUMAR DESAI., ADVOCATE FOR R1; SRI.M R RAJAGOPAL., SENIOR COUNSEL A/W SRI.B M SHIVAJI., ADVOCATE FOR R2) THIS RFA CROB IS FILED UNDER ORDER 41 RULE 22(2) OF CPC., AGAINST THE JUDGMENT AND DECREE DATED 13.01.2015 PASSED

PR.COMMISSIONER OF vs. M/S TRIANZ HOLDINGS 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

PR COMMISSIONER OF vs. M/S ZYME SOLUTIONS P 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

THE PR COMMISSIONER OF INCOME TAX CIT(A) vs. M/S GENISYS INFORMATION

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