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320 results for “transfer pricing”+ Section 83clear

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Key Topics

Addition to Income49Section 26031Section 10A6Section 260A4Section 10B4Comparables/TP4Section 1483Section 1473Section 43

THE PRINCIPAL COMMISSIONER vs. M/S OBULAPURAM MINING

ITA/100012/2017HC Karnataka17 Mar 2023

Bench: K.SOMASHEKAR,UMESH M ADIGA

Section 143(3)Section 144CSection 144C(13)Section 260ASection 37(1)Section 92ASection 92C

price has to be computed under section 92C of the Act, in the cases relating to an international transaction. The term international transaction has been defined in section 92B of the Act. Subsection (1) section 92B eads as under" for the purpose of this Act and section 92, 92C, 92D and 92E, International transaction" means a transaction between

XIAOMI TECHNOLOGY INDIA PRIVATE LIMITED vs. DEPUTY COMMISSIONER OF INCOME TAX

Showing 1–20 of 320 · Page 1 of 16

...
Depreciation3
Transfer Pricing3
Section 45(4)2

In the result, I pass the following:

WP/16692/2022HC Karnataka16 Dec 2022

Bench: The Hon'Ble Mr.Justice S.R.Krishna Kumar

Section 281BSection 281ESection 92C

transfer pricing adjustment. Pursuant to the said order, the Assessing Officer issued a Notice under Section 142(1) of the I.T.Act for the Assessment Year 2018-19 inter alia calling upon the petitioner to show cause, as to why payment of royalty to the foreign entity i.e., Qualcomm and Beijing Xiaomi Mobile should not be disallowed. On 10.08.2022, petitioner submitted

THE COMMISSIONER OF INCOME TAX vs. M/S SHASTHA PHARMA LABORATORIES

The appeal is dismissed

ITA/331/2007HC Karnataka27 Nov 2013

Bench: N.KUMAR,RATHNAKALA

Section 143(3)Section 147Section 148Section 2Section 260Section 45Section 45(4)

83,400/- on 28.12.1992. After considering assessment under Section 143(3) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’), an order came to be passed on 11.11.1994 treating the assesee as the unregistered firm and accepting the return filed. The assessment - 3 - was reopened by issuing notice under Section 148 of the Act on 19.12.2000, after

COMMISSIONER OF INCOME TAX vs. SRI.M.R.JANAKIRAM (HUF)

The appeal is allowed

WTA/19/2015HC Karnataka29 Jan 2020

Bench: ARAVIND KUMAR,E.S.INDIRESH

Section 449Section 456Section 456(1)Section 456(2)Section 483

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

ITA/70/2007HC Karnataka26 Sept 2012

Bench: The Hon’Ble Mr. Justice N.K.Sudhindrarao R.S.A.No.70/2007

Section 100

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 or other intangible thing, can be made only by a registered instrument. 1In the case of tangible immoveable property of a value

COMMISSIONER OF INCOME TAX-III vs. M/S YODLEE INFOTECH PVT LTD

The appeal is disposed of

ITA/51/2014HC Karnataka28 Sept 2020

Bench: ALOK ARADHE,M.I.ARUN

Section 10BSection 115JSection 143(1)Section 260Section 260ASection 92C

83,628/- under Section 10B of the Act and Rs.3,05,84,109/- as book profits under Section 115JB of the Act was claimed. The return was processed under Section 143(1) of the Act and was subsequently taken up for scrutiny. As the International transactions of the assessee were in excess of Rs.10 Crores, a reference under Section 92CA

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

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

ITA/211/2009HC Karnataka25 Mar 2015

Bench: N.KUMAR,B.SREENIVASE GOWDA

Section 260

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

PR COMMISSIONER OF vs. M/S WIPRO LIMITED

In the result, the appeal is disposed of in terms

ITA/464/2017HC Karnataka09 Dec 2020

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 10ASection 260Section 260ASection 32

section 10A nor under the provisions of the DTAA? (12) Whether on the facts and in the circumstances of the case, the Tribunal is right in law in setting aside the allocation of corporate expenses for the purpose of deduction in respect of 10A and non-10A units by placing reliance on the orders passed in respect of earlier assessment

M/S FIDELITY BUSINESS SERVICES INDIA PVT LTD vs. ASSISTANT COMMISSIONER OF INCOME TAX

ITA/512/2017HC Karnataka23 Jul 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 2(22)(e)Section 254Section 260

83,62,21,764/-]. 8. Since the said Assessment Order was passed in pursuance of the directions of the Dispute Resolution Panel (DRP) under Section 144 C (5) of the Income Tax Act, 1961, the Assessee Company preferred an appeal before the learned Income Tax Appellate Tribunal (ITAT), who disposed of the said appeal by the impugned Order dated 22/02/2017

SMT. M R PRABHAVATHY vs. THE DEPUTY COMMISSIONER OF INCOME TAX

WTA/1/2019HC Karnataka04 Mar 2020

Bench: The Hon’Ble Mr. Justice K.Natarajan Election Petition No.1 Of 2019 Connected With Election Petition No.2 Of 2019

Section 81

Section 33A of RP Act and 106 he has committed corrupt practice of bribery as contemplated under Sections 123(1)(A), 123(1)(B), 123(7), 123(7)(b), 123(vii)(d), 123(7)(h) and Section 123(8), 123(3), 3A and 123(6) of R.P. Act ? The petitioner in E.P. No.2/2019 has contended that respondent No.1 committed corrupt

PR COMMISSIONER OF INCOME TAX vs. M/S RAMBUS CHIP TECHNOLOGIES INDIA PVT LTD

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

ITA/83/2021HC Karnataka25 Sept 2024

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

Section 260

83 of 2021 ORAL JUDGMENT (PER: HON'BLE MR JUSTICE S.G.PANDIT) Heard the learned counsel Sri. Sanmathi.E.I., for appellants/Revenue and learned counsel Smt.Tanmayee Rajkumar for respondent/assessee. 2. The Revenue is in appeal under Section 260-A of the Income Tax Act, 1961 (for short ‘the Act’) questioning the correctness and legality of order dated 10.01.2020 passed by the Income

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

In the result, we pass the following order:

WA/3403/2011HC Karnataka07 Sept 2011

Bench: RAVI MALIMATH,N.KUMAR

Section 4

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

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

HERBALIFE INTERNATIONAL INDIA PVT LTD vs. THE COMMISSIONER OF INCOME TAX

In the result, the assessee's appeal for

ITA/433/2018HC Karnataka20 May 2025

Bench: V KAMESWAR RAO,S RACHAIAH

Section 143(3)Section 144CSection 260Section 263

Transfer Pricing Adjustment of ALP, Doubtful Debts Written Off, Administrative Fees. According to him, no enquiry in the matter of Assessee’s claim for 100% depreciation on leasehold improvements was conducted by the Assessing Officer is established by the admission of the AR of the Assessee before the learned CIT on 13.12.2014 in the course of revisionary proceedings. 14. According

M/S LAKSHMINARAYANA MINING COMPANY vs. STATE OF KARNATAKA

In the result, these petitions must succeed

WP/44729/2016HC Karnataka04 Oct 2017

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

83 and other judicial pronouncements. Therefore, without altering the basis of the judicial pronouncements, the State could not have brought in the amendment only by adding explanations; (iii) No fee is leviable unless there is a quid pro quo in the form of a service or benefit; 12. The petitions are opposed by the State by filing the Statement

M/S PADMAVATHI FERROUS LTD vs. GOVERNMENT OF KARNATAKA

In the result, these petitions must succeed

WP/49694/2016HC Karnataka04 Oct 2017

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

83 and other judicial pronouncements. Therefore, without altering the basis of the judicial pronouncements, the State could not have brought in the amendment only by adding explanations; (iii) No fee is leviable unless there is a quid pro quo in the form of a service or benefit; 12. The petitions are opposed by the State by filing the Statement

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

In the result, these petitions must succeed

WP/46963/2016HC Karnataka04 Oct 2017

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

83 and other judicial pronouncements. Therefore, without altering the basis of the judicial pronouncements, the State could not have brought in the amendment only by adding explanations; (iii) No fee is leviable unless there is a quid pro quo in the form of a service or benefit; 12. The petitions are opposed by the State by filing the Statement

MUKUND LIMITED vs. STATE OF KARNATAKA

In the result, these petitions must succeed

WP/43949/2016HC Karnataka04 Oct 2017

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

83 and other judicial pronouncements. Therefore, without altering the basis of the judicial pronouncements, the State could not have brought in the amendment only by adding explanations; (iii) No fee is leviable unless there is a quid pro quo in the form of a service or benefit; 12. The petitions are opposed by the State by filing the Statement

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

In the result, these petitions must succeed

WP/44271/2016HC Karnataka04 Oct 2017

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

83 and other judicial pronouncements. Therefore, without altering the basis of the judicial pronouncements, the State could not have brought in the amendment only by adding explanations; (iii) No fee is leviable unless there is a quid pro quo in the form of a service or benefit; 12. The petitions are opposed by the State by filing the Statement