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448 results for “transfer pricing”+ Section 9(1)(v)clear

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Key Topics

Section 26058Addition to Income32Section 92C15Section 260A14Section 14814Transfer Pricing13Section 14A11Deduction11Section 143(2)

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

v. CTO, (1997) 106 STC 433, 439 (SC)]. Therefore, following this principle, we hold that since the parameters laid down in sub-section (1) are not fulfilled, there is no relationship of AE between assessee-company and JII and therefore, the provisions of chapter X of the Act have no application. 11.2 In the result, the transfer pricing adjustment made

DEVAS MULTIMEDIA PRIVATE LIMITED vs. THE PRINCIPAL COMMISSIONER OF INCOME-TAX

Showing 1–20 of 448 · Page 1 of 23

...
9
Section 143(3)9
Section 1479
Disallowance8
WP/11618/2016HC Karnataka27 Sept 2019

Bench: The Hon’Ble Mr.Justice P.B. Bajanthri Writ Petition No.11618 Of 2016 (T-It) Between:

Section 142(4)Section 143(2)Section 143(3)Section 144Section 144CSection 263Section 92C

9. It is submitted that the issue to taxability of shares being issued at a premium has already been well settled. The Revenue had raised a similar issue regarding discrepancy in valuation of the share premium received in the case of Vodafone India Services (P) Ltd vs UOI (2014) 368 ITR 1 (Bom). A transfer 12 pricing adjustment was made

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 u/s 143(1

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 u/s 143(1

PR COMMISSIONER OF vs. M/S SOFTBRANDS INDIA

ITA/536/2015HC Karnataka25 Jun 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 260

1) (d) of the Act. Section 254 of the Act empowers the Appellate Tribunal to pass such orders on the appeals ‘as it thinks fit’ after giving an opportunity of hearing to both the parties. 38. From the aforesaid Scheme of assessment with regard to international transactions, it is clear that the process of determination of ‘Arm’s Length Price

PR COMMISSIONER OF vs. M/S SOFTBRANDS INDIA

ITA/537/2015HC Karnataka25 Jun 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 260

1) (d) of the Act. Section 254 of the Act empowers the Appellate Tribunal to pass such orders on the appeals ‘as it thinks fit’ after giving an opportunity of hearing to both the parties. 38. From the aforesaid Scheme of assessment with regard to international transactions, it is clear that the process of determination of ‘Arm’s Length Price

PR. COMMISSIONER OF INCOME TAX-5 vs. M/S. PUMA SPORTS INDIA P., LTD.,

The appeal stands dismissed

ITA/223/2018HC Karnataka12 Mar 2021

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

Section 143(3)Section 144Section 260Section 40Section 5(2)(b)Section 9(1)(i)Section 92C

transfer pricing adjustment for Rs.4,16,65,106/- on the basis of the order passed under Section 92CA of the Act dated 24.10.2016. The assessing authority also made other additions. The assessee’s objections were not considered by the Dispute Resumption Panel and therefore, an appeal was 3 filed before the Income Tax Appellate Tribunal, Bangalore (hereinafter referred

M/S SREE JAYALAKSHMI TEXTILES vs. M/S INTERNATIONAL ASSET RECONSTRUCTION

WP/22348/2015HC Karnataka15 Dec 2015

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)

transfer by way of sale, lease or otherwise (other than in the ordinary course of his business) any of his secured assets referred to in the notice, without prior written consent of the secured creditor.” xxx 17. Right to appeal .-(1) Any person (including borrower), aggrieved by any of the measures referred to in sub-section (4) of section

M/S SREE JAYALAKSHMI TEXTILES vs. M/S INTERNATIONAL ASSET RECONSTRUCTION

WP/29362/2015HC Karnataka15 Dec 2015

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)

transfer by way of sale, lease or otherwise (other than in the ordinary course of his business) any of his secured assets referred to in the notice, without prior written consent of the secured creditor.” xxx 17. Right to appeal .-(1) Any person (including borrower), aggrieved by any of the measures referred to in sub-section (4) of section

THE COMMISSIONER OF INCOME TAX vs. M/S WIPRO LTD

In the result, the appeals are partly allowed

ITA/133/2007HC Karnataka23 Aug 2013

Bench: B.MANOHAR,DILIP B.BHOSALE

Section 260

1. THE COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, C.R.BUILDING QUEENS ROAD, BANGALORE 2. THE DEPUTY COMMISSIONER OF INCOME TAX SPECIAL RANGE-IV(A), MUMBAI ... APPELLANTS (BY SRI K V ARAVIND, ADV.,) AND M/S WIPRO LTD C/O SHRI.K.R.PRADEEP, C.A NO.120, EDEN PARK, 101, I FLOOR VITTAL MALLYA ROAD, BANGALORE ... RESPONDENT (BY SMY S R ANURADHA , ADV.,) THIS ITA FILED U/S.260-A

WIPRO LIMITED vs. THE JOINT COMMISSIONER OF INCOME TAX

WP/20040/2019HC Karnataka25 Aug 2021

Bench: The Hon’Ble Mr. Justice Krishna S.Dixit Writ Petition No.20040/2019 (T-It) Between:

Section 1Section 143(2)Section 143(3)Section 244ASection 254Section 92C

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

SHRI. PARSWANATH vs. ASSISTANT COMMISSIONER OF INCOME TAX

ITA/304/2019HC Karnataka13 Sept 2021

Bench: The Hon'Ble Mr. Justice M. Nagaprasanna

Section 109Section 13(1)(e)Section 13(2)Section 397Section 482

price in buying or selling. [Wharton's Law Lexicon, 1976 Reprint Ed.]. Expression “abatement” has been separately spelt out, in the same dictionary. “Abatement of criminal proceedings” has been termed to mean their termination 26 without a decision on the merits and without the assent of the prosecutor. If this is the legal position or meaning of abatement

THE MANGALORE ELECTRICITY SUPPLY COMPANY LTD., vs. SRI A CHANDRASEKHAR

WP/15230/2022HC Karnataka17 Oct 2022

Bench: G.NARENDAR,P.N.DESAI

price fixed under any law, etc. 29. Deficiency of service is defined under Section 2(1)(g) of the Consumer Protection Act, 1986 in the following manner: “2. (1)(g) ‘deficiency’ means any fault, imperfection, shortcoming or inadequacy in the quality, nature and manner of performance which is required to be maintained by or under any law for the time

MR. BINEESH KODIYERI vs. DIRECTORATE OF ENFORCEMENT

WP/13261/2020HC Karnataka16 Mar 2021

Bench: The Hon’Ble Mr. Justice Suraj Govindaraj Writ Petition No. 13261 Of 2020 (Gm-Res) Between: Mr. Bineesh Kodiyeri S/O Mr. Kodiyeri Balakrishnan Aged About 37 Years Kootamvilla Lane, Maruthankuzhi Thiruvananthapuram District Kerala State – 695013

Section 19Section 482

price of which exceeds on e crore rupees; or (d) Fraudulently availing of or attempt to avail of drawback or any exemption from duty provided under this Act, if the amount of drawback or exemption from duty exceeds fifty lakh rupees. WP No. 13261 of 2020 65 (7) Save as otherwise provided in sub-section (6), all other offences under

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

ITA/107/2025HC Karnataka12 Sept 2025

Bench: CHIEF JUSTICE,C M JOSHI

Section 10ASection 14ASection 260Section 260A

Transfer Pricing Officer and to avoid rigors of Section 92C(4) of the Act and consequently enhanced benefits under section 10AA of the Act"? (ii) "Whether on facts and circumstances of the case, the Tribunal's order can be said as perverse in nature in not appreciating that the assesee failed to substantiate an furnish details

THE PR. COMMISSIONER OF INCOME TAX vs. M/S GOLDMAN SACHS SERVICES PVT LTD

ITA/29/2019HC Karnataka10 Jun 2021

Bench: The Hon'Ble Mr. Justice V. Srishananda Civil Revision Petition No.29/2019 Between

Section 115Section 37(2)

V SRISHANANDA) The present Civil Revision Petition is a classic example of how an arbitration proceedings can be delayed even at the very inception stage in utter disregard to the laudable object of early resolution of civil dispute and Alternate Dispute Resolution System and defeating the very object 4 of the enactment of Arbitration and Conciliation

NOVO NORDISK INDIA PRIVATE LIMITED vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 12 (2

WP/21206/2014HC Karnataka25 Jun 2018

Bench: S.SUJATHA

Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 149Section 152Section 92B(2)Section 92C

Transfer Pricing Officer under Section 92CA(1) of the Act for determination of arm’s length price in respect of international transactions - 4 - reported by the petitioner during the subject Assessment year. TPO passed a detailed order under Section 92CA(3) of the Act accepting the arm’s length price reported by the petitioner in respect of its international transactions

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

M. NARAYANAPPA vs. THE STATE OF KARNATAKA

WP/14620/2014HC Karnataka30 Sept 2015

Bench: The Hon’Ble Mr.Justice Aravind Kumar

price of the liquor being sold to the customers depending upon the varying degree of facilities provided by them to the customers. 28. The Legislature has inserted Entry 59A in the III Schedule to KVAT Act and has chosen to provide for levy of tax on liquor sold by certain licence holders. Notification – II bearing No.FD 21 CSL 2014 dated

SRI M MADHAVA GOWDA vs. UNDER SECRETARY TO GOVERNMENT

WP/27825/2014HC Karnataka30 Sept 2015

Bench: The Hon’Ble Mr.Justice Aravind Kumar

price of the liquor being sold to the customers depending upon the varying degree of facilities provided by them to the customers. 28. The Legislature has inserted Entry 59A in the III Schedule to KVAT Act and has chosen to provide for levy of tax on liquor sold by certain licence holders. Notification – II bearing No.FD 21 CSL 2014 dated