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3 results for “transfer pricing”+ Undisclosed Incomeclear

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Key Topics

Section 158B3Section 2602Section 2542Section 2(22)(e)2Section 260A2Section 2632Penalty2

DR SYED ANWAR vs. THE DEPUTY COMMISSIONER OF INCOME-TAX

Appeal is allowed

ITA/421/2014HC Karnataka18 Oct 2022

Bench: P.S.DINESH KUMAR,T.G. SHIVASHANKARE GOWDA

Section 143(3)Section 158BSection 260

undisclosed amount given as 'on-money' to the sellers. 11. In Assistant Commissioner of Income-Tax -vs- Hotel Blue Moon2, it is held that the assessment for the 2 (2010) 188 Taxman 113 - 10 - ITA.421/2014 block period can only be done on the basis of evidence found as a result of search or requisition of books of account or documents

THE PR COMMISSIONER OF INCOME TAX vs. SHRI H NAGARAJA

ITA/605/2017HC Karnataka29 May 2018

Bench: S SUNIL DUTT YADAV,B.S PATIL

Section 153ASection 260ASection 263Section 271(1)(c)

undisclosed profit for the respective assessment years. 20. The assessee challenged this order by filing appeal before the Appellate Commissioner. The Appellate Authority considered both the appeals and in his order dated 28.03.2013, has held after examining the legality and correctness of the order passed by the Assessing Officer that addition made by the Assessing Officer regarding unexplained income

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

transfer of the reserves and surplus to the holding company by avoiding the payment of tax and therefore it will be treated as a colourable device. There are two aspects in this transaction- (i) It is a simple and plain transaction of buy back of shares without having any dispute of price then the same is beyond the scope