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312 results for “transfer pricing”+ Section 91clear

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Key Topics

Addition to Income56Section 26024Section 14A4Section 43Section 1002

COMMISSIONER OF INCOME-TAX vs. M.R.SAMPANGIRAMAIAH

ITA/178/2015HC Karnataka22 Jul 2022

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

Section 96

transfer pendente lite automatically does not become void, but the decree for Specific Performance binds the transferee vide HARDEV SINGH vs. GURMAIL SINGH14, whether he is a party eo nomine to the proceeding or not. In the latter, the transaction is void, if 13 2024 INSC 770. 14 AIR 2007 SC 1058 - 53 - RFA No.178 OF 2015 C/W RFA CROB

THE PR. COMMISSIONER OF INCOME TAX vs. M/S EDS ELECTRONICS DATA SYSTEMS INDIA PVT.LTD.

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

ITA/680/2015HC Karnataka15 Jan 2021

Bench: ALOK ARADHE,R. NATARAJ

Section 10ASection 143(3)

Showing 1–20 of 312 · Page 1 of 16

...
Section 260
Section 260A
Section 80H

Section 80HHE in respect of profits derived from export of computer software available to any entity. However, the Transfer Pricing Officer by order dated - 06.05.2006 considered the loss of 14.76% in the entire technical consultancy services agreement and was of the view that since, independent parties had an average margin of 17.02% therefore, there ought to be an adjustment. Thus

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

Section 10AA of the Act. In addition, the Assessee had also claimed deduction under Chapter VI-A of the Act. Immediately after filing its original return for AY 2015-16, the Assessee had filed a revised return voluntarily declaring transfer pricing [TP] adjustments of ₹14,82,00,000/-, which was reworked at ₹21,36,91

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

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 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

Section 54 of the Transfer of Property Act, reads as under: 54. “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.— 3Such transfer, in the case of tangible immoveable property of the value of one hundred rupees and upwards, or in the case

THE PRINCIPAL COMMISSIONER OF INCOME TAX -2 vs. M/S MICROCHIP TEHNOLOGIES INDIA PVT LTD

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

ITA/585/2022HC Karnataka24 Sept 2024

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

Section 260

Section 260-A of the Income Tax Act, 1961 (for short, ‘the Act’) questioning the correctness and legality of order dated 14.06.2021 passed by the Income Tax Appellate Tribunal, - 3 - NC: 2024:KHC:39712-DB ITA No. 585 of 2022 ‘A’ Bench, Bengaluru (for short, ‘Appellate Authority’) in ITA.No.323/Bang/2019 for the assessment year 2010-11, raising the following substantial

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

Section 66 thereof created charge of service tax in regard to taxable services. Service Lax’ is defined in clause (34) of Set lion 65 to mean tax chargeable under the provLsioi is of that napler. 7’axable ceri’icc is dejrnea Iunder sub ‘‘larcsc’ Ib) 1 ½usc 4 1 [ 5j 0 n ° mc a an, srvkc provided tu. znrcr cilia

CHITTHARANJAN A DASANNACHARYA vs. THE COMMISSIONER OF INCOME TAX-V

In the result, the appeal is allowed

ITA/153/2014HC Karnataka23 Oct 2020

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 143(3)Section 2(14)Section 2(47)Section 260Section 260ASection 54F

price of shares and market value of shares on the date of exercise of 'income from short term capital 6 gains'. The claims for deduction under Section 54F was disallowed. The assessee thereupon approached the Commissioner of Income Tax (Appeals) who by an order dated 31.10.2011 dismissed the appeal on merits. However, the interest levied under Section 234B

SHRI A KHADAR BASHA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

Appeal is allowed

ITA/1130/2008HC Karnataka20 Jan 2015

Bench: B.VEERAPPA,N.KUMAR

Section 145(3)Section 260ASection 40

91) ITR 8 has held that “where a trader transfers his goods to another trader at a price less than the market price and the transaction is a bonafide one, the taxing authority cannot take into account the market price of those - 5 - goods, ignoring the real price fetched to ascertain the profit from the transaction. An assessee

SMT. S. JALAJA vs. UNION OF INDIA

In the result, writ appeals are allowed

WA/1105/2019HC Karnataka24 Aug 2021

Bench: ALOK ARADHE,HEMANT CHANDANGOUDAR

Section 4

91 and First Schedule of the 2013 Act submitted that even provisions pertaining to determination of compensation contained in both the enactments are not in conflict with each other. Our attention has also been invited to resolution dated 27.08.2016 passed by the Board by which it has resolved to take into account the components mentioned in First Schedule appended

THE PR. COMMISSIONER OF INCOME-TAX vs. M/S. ARIS GLOBAL SOFTWARE PVT. LTD.,

ITA/995/2017HC Karnataka13 Aug 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 10ASection 260

Transfer Pricing Officer has considered the comparables on the basis of qualitative and quantitative filters? 2. Whether on the facts and in the circumstances of the case, Tribunal is right in law in setting aside the recomputation of 10A deduction made by assessing authority by following the judgment of this Hon’ble High Court in the case

M/S. HOTHUR TRADERS vs. STATE OF KARNATAKA

In the result, these petitions must succeed

WP/44105/2016HC Karnataka04 Oct 2017

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

price of forest produce was within the legislative competence of the State under Entry 54 of List-II and constitutionally valid. Although the unamended section 98A(1) refers to the levy of a tax, the impost is more in the nature of a fee. The amount collected by way of forest development tax is earmarked for development and regeneration

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

In the result, these petitions must succeed

WP/43969/2016HC Karnataka04 Oct 2017

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

price of forest produce was within the legislative competence of the State under Entry 54 of List-II and constitutionally valid. Although the unamended section 98A(1) refers to the levy of a tax, the impost is more in the nature of a fee. The amount collected by way of forest development tax is earmarked for development and regeneration

IRON ORE END USERS ASSOCIATION vs. STATE OF KARNATAKA

In the result, these petitions must succeed

WP/43951/2016HC Karnataka04 Oct 2017

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

price of forest produce was within the legislative competence of the State under Entry 54 of List-II and constitutionally valid. Although the unamended section 98A(1) refers to the levy of a tax, the impost is more in the nature of a fee. The amount collected by way of forest development tax is earmarked for development and regeneration

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

price of forest produce was within the legislative competence of the State under Entry 54 of List-II and constitutionally valid. Although the unamended section 98A(1) refers to the levy of a tax, the impost is more in the nature of a fee. The amount collected by way of forest development tax is earmarked for development and regeneration

SATHVAHANA ISPAT LIMITED vs. STATE OF KARNATAKA

In the result, these petitions must succeed

WP/43871/2016HC Karnataka04 Oct 2017

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

price of forest produce was within the legislative competence of the State under Entry 54 of List-II and constitutionally valid. Although the unamended section 98A(1) refers to the levy of a tax, the impost is more in the nature of a fee. The amount collected by way of forest development tax is earmarked for development and regeneration

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

price of forest produce was within the legislative competence of the State under Entry 54 of List-II and constitutionally valid. Although the unamended section 98A(1) refers to the levy of a tax, the impost is more in the nature of a fee. The amount collected by way of forest development tax is earmarked for development and regeneration

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

price of forest produce was within the legislative competence of the State under Entry 54 of List-II and constitutionally valid. Although the unamended section 98A(1) refers to the levy of a tax, the impost is more in the nature of a fee. The amount collected by way of forest development tax is earmarked for development and regeneration

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

In the result, these petitions must succeed

WP/53987/2016HC Karnataka04 Oct 2017

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

price of forest produce was within the legislative competence of the State under Entry 54 of List-II and constitutionally valid. Although the unamended section 98A(1) refers to the levy of a tax, the impost is more in the nature of a fee. The amount collected by way of forest development tax is earmarked for development and regeneration