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

Bench: CHIEF JUSTICE,C M JOSHI

79,542 - 7 - HC-KAR NC: 2025:KHC:36360-DB ITA No. 107 of 2025 C/W ITA No. 106 of 2025 Add: Voluntary TP adjustment 36,90,62,637 Income from business of the undertaking after voluntary TP adjustment 80,51,42,179 7. The AO had denied the exemption under Section 10AA on the TP pricing adjustment made pursuant

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 54 of the Transfer of Property Act, as under: “Sale” defined.—‘‘Sale” is a transfer of ownership in exchange for a price paid or promised or part- paid and part-promised. Sale how made.—Such transfer, in the case of tangible immoveable property of the value of one hundred rupees and upwards, or in the case of a reversion

M/S. EVERGREEN HARDWARE STORES vs. THE ASSISTANT COMMISSIONER OF

Appeal is allowed

Bench: P.S.DINESH KUMAR,UMESH M ADIGA

79,298/- is to be taken as deemed profit on transfer of stock and consequently passed a perverse order on the facts and circumstances of the case. 4. Whether the Tribunal was justified in confirming the disallowance of Rs.53,367/- under Section 14A of the Act on the facts and circumstances of the case. 5. Whether the Tribunal was justified

M/S INDUS TOWERS LTD vs. THE DEPUTY COMMISSIONER OF COMMERCIAL TAXES

In the result, we pass the following order:

Bench: RAVI MALIMATH,N.KUMAR

price! work of the respondent or riioz’e it out during the period the machinery was in his use: the condition that 11 me contractor i could be respom isible tor the (‘ustodq of the machinery mehile it was on (lie site did not militate aqatnst respondents possession and ontrol of th rnachmenj ReIiar 1 R ciiu

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

THE PR.COMMISSIONER OF vs. M/S MAHAVEER CALYX

In the result, the orders passed by the Assessing

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

price as well as the terms and conditions. The aforesaid quotation states that Dell product would be exported from Malaysia. Thus, the petitioner seeks customer's upfront contractual approval of manufacture and supply of required product from Malaysia. On receipt of the quotation, customer accepts either by signing the same or by raising a purchase order or by making

SMT DURGA KUMARI BOBBA vs. THE DEPUTY COMMISSIONER

Appeal is allowed in

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

transfer nor as cost of acquisition, the only two contingencies which can be considered while allowing deduction. The tax component does not fall within the definition of Section 48(1) of the Act; • that the tax paid by the company is not allowed as deduction. By the same analogy, deduction 5 cannot be allowed in the hands of the appellant

PR. COMMISISONER OF INCOME TAX - 3, vs. M/S INFINEON TECHNOLOGIES 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?" 4. "Whether on the facts and in the circumstances of the case, the Tribunal is right in allowing working capital adjustment without an upper limit would result into abnormal adjustment and would make the profit earned within the permitted range even when if no operating profit is earned and the upper limit of working capital adjustment should

M/S. BMM ISPAT LTD vs. THE STATE OF KARNATAKA

In the result, these petitions must succeed

Bench: ABHAY SHREENIWAS OKA (CJ),P.S.DINESH KUMAR

79 4. The validity of levy under Section 98-A of the Forest Act was challenged in this Court, contending inter alia that the said levy was in fact a fee, and such a fee could not have been levied as there was no quid pro quo with reference to the quantum of levy. This Court, in the case

IRON ORE END USERS ASSOCIATION vs. STATE OF KARNATAKA

In the result, these petitions must succeed

Bench: ABHAY SHREENIWAS OKA (CJ),P.S.DINESH KUMAR

79 4. The validity of levy under Section 98-A of the Forest Act was challenged in this Court, contending inter alia that the said levy was in fact a fee, and such a fee could not have been levied as there was no quid pro quo with reference to the quantum of levy. This Court, in the case

M/S. HOTHUR TRADERS vs. STATE OF KARNATAKA

In the result, these petitions must succeed

Bench: ABHAY SHREENIWAS OKA (CJ),P.S.DINESH KUMAR

79 4. The validity of levy under Section 98-A of the Forest Act was challenged in this Court, contending inter alia that the said levy was in fact a fee, and such a fee could not have been levied as there was no quid pro quo with reference to the quantum of levy. This Court, in the case

HINDUSTAN CALCINED METALS PRIVATE LIMITED vs. STATE OF KARNATAKA

In the result, these petitions must succeed

Bench: ABHAY SHREENIWAS OKA (CJ),P.S.DINESH KUMAR

79 4. The validity of levy under Section 98-A of the Forest Act was challenged in this Court, contending inter alia that the said levy was in fact a fee, and such a fee could not have been levied as there was no quid pro quo with reference to the quantum of levy. This Court, in the case

M/S ELECTROTHERM (INDIA)LTD vs. THE STATE OF KARNATAKA

In the result, these petitions must succeed

Bench: ABHAY SHREENIWAS OKA (CJ),P.S.DINESH KUMAR

79 4. The validity of levy under Section 98-A of the Forest Act was challenged in this Court, contending inter alia that the said levy was in fact a fee, and such a fee could not have been levied as there was no quid pro quo with reference to the quantum of levy. This Court, in the case

M/S S.V.CHETTY IRON ORE MINES vs. STATE OF KARNATAKA

In the result, these petitions must succeed

Bench: ABHAY SHREENIWAS OKA (CJ),P.S.DINESH KUMAR

79 4. The validity of levy under Section 98-A of the Forest Act was challenged in this Court, contending inter alia that the said levy was in fact a fee, and such a fee could not have been levied as there was no quid pro quo with reference to the quantum of levy. This Court, in the case

M/S HARE KRISHNA METALICS PVT LTD vs. STATE OF KARNATAKA

In the result, these petitions must succeed

Bench: ABHAY SHREENIWAS OKA (CJ),P.S.DINESH KUMAR

79 4. The validity of levy under Section 98-A of the Forest Act was challenged in this Court, contending inter alia that the said levy was in fact a fee, and such a fee could not have been levied as there was no quid pro quo with reference to the quantum of levy. This Court, in the case

M/S JEEVAKA INDUSTRIES PRIVATE LIMITED vs. STATE OF KARNATAKA

In the result, these petitions must succeed

Bench: ABHAY SHREENIWAS OKA (CJ),P.S.DINESH KUMAR

79 4. The validity of levy under Section 98-A of the Forest Act was challenged in this Court, contending inter alia that the said levy was in fact a fee, and such a fee could not have been levied as there was no quid pro quo with reference to the quantum of levy. This Court, in the case

KIRLOSKAR FERROUS INDUSTRIES LIMITED vs. THE STATE OF KARNATAKA

In the result, these petitions must succeed

Bench: ABHAY SHREENIWAS OKA (CJ),P.S.DINESH KUMAR

79 4. The validity of levy under Section 98-A of the Forest Act was challenged in this Court, contending inter alia that the said levy was in fact a fee, and such a fee could not have been levied as there was no quid pro quo with reference to the quantum of levy. This Court, in the case