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 INCOME TAX-5 vs. M/S NOVELL SOFTWARE DEVELOPMENT (INDIA) PVT.LTD.

In the result, we do not find any merit in this appeal

Bench: ALOK ARADHE,R. NATARAJ

Transfer Pricing Officer, there is a definite impact on the net margins of the assessee as compared to comparable companies. Therefore, there is a need of making an adjustment to eliminate differences into accounting policies of the assessee and the comparable companies in terms of the Rules. It is also argued that Tribunal has rightly accepted the aforesaid submission

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

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

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

57 (SC) and ‘GVK INDUSTRIES LTD. VS. INCOME TAX OFFICER’, (2011) 332 ITR 130 (SC). 5. On the other hand, learned counsel for the revenue submitted that as per Section 45 of the Act, transfer of entire business of firm to company amounts 10 to transfer of capital asset. It is further submitted that Section 47(xiii) only takes

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

price paid for the land in question. Therefore, there is no scope for plea of poverty. It has come in the evidence of DW.1 that this defendant was informed of plaintiff’s transaction. As a businessman, he ought to have made reasonable enquiry, obviously that would include about the court proceedings. What enquiries were made

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

THE COMMISSIONER OF INCOME TAX vs. M/S FOSROC CHEMICALS INDIA PVT LTD

The appeals are dismissed

Bench: B.V.NAGARATHNA,JAYANT PATEL

57,135/- to the AE was an independent international transaction which had to be analysed by applying CUP method prescribed by Rule 10B (1)(a) of the Act”? 5 Substantial questions of law in ITA No.470/2013 “1. Whether on the facts and in the circumstances and in law the Tribunal was correct is setting aside the determination

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