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11 results for “transfer pricing”+ Deductionclear

Sorted by relevance

Mumbai3,476Delhi3,083Bangalore1,507Chennai857Kolkata656Ahmedabad600Pune518Hyderabad475Karnataka400Jaipur344Chandigarh253Cochin191Indore172Surat109Rajkot101Visakhapatnam98Cuttack74SC67Telangana57Lucknow53Raipur45Nagpur43Amritsar35Calcutta31Jodhpur30Agra29Dehradun21Ranchi13Varanasi12Kerala11Panaji11Guwahati11Jabalpur11Allahabad10A.K. SIKRI ROHINTON FALI NARIMAN7Rajasthan7Patna4Orissa4T.S. THAKUR ROHINTON FALI NARIMAN1Andhra Pradesh1MADAN B. LOKUR S.A. BOBDE1Punjab & Haryana1DIPAK MISRA V. GOPALA GOWDA1A.K. SIKRI N.V. RAMANA1

Key Topics

Section 143(3)7Deduction5Section 92C4Section 36(1)(iii)4Transfer Pricing4Disallowance4Addition to Income3Section 144C2Section 352Section 144C(5)

THE PRINCIPAL COMMISSIONER OF INCOME TAX vs. M/S. APOLLO TYRES LTD

Appeal is allowed in part as indicated

ITA/44/2017HC Kerala22 Sept 2021

Bench: HONOURABLE MR.JUSTICE S.V.BHATTI,HONOURABLE MR.JUSTICE VIJU ABRAHAM

For Appellant: M/S. APOLLO TYRES LTDFor Respondent: THE PRINCIPAL COMMISSIONER OF INCOME TAX
Section 143(3)Section 144CSection 144C(5)Section 35Section 43ASection 92C

Transfer Pricing Officer-1, Kochi, made the order under Section 92CA(3) ITA No.44/2017 -3- of the Act. The Assessing Officer through Annexure-B draft assessment order dated 28.03.2014 proposed to finalize the income tax return of the assessee assessed total income as Rs.481,78,02,530/-. The assessee raised objections to the draft assessment order dated 28.03.2014. The issues

2

M/S. JOYALUKKAS INDIA LTD, vs. THE ASSISTANT COMMISSIONER OF INCOME TAX,

In the result, the appeal fails and the substantial questions

ITA/10/2019HC Kerala21 Dec 2022

Bench: HONOURABLE MR.JUSTICE S.V.BHATTI,HONOURABLE MR.JUSTICE BASANT BALAJI

For Appellant: M/S.JOYALUKKAS INDIA LTDFor Respondent: THE ASSISTANT COMMISSIONER OF INCOME TAX
Section 143Section 143(1)Section 143(3)Section 144CSection 36(1)(iii)Section 92C

Transfer I.T.A. No.10/2019 3 Pricing Officer and resulted in a draft order dated 25.03.2014 under Section 143(3) read with 144C(1) of the Act. Though objections to the draft order were filed before the dispute resolution panel, the panel vide order dated 29.12.2014 upheld some of the additions proposed in the draft assessment order and thereafter the respondent passed

THE PRINCIPAL COMMISSIONER OF INCOME TAX vs. USHA MURUGAN

ITA/18/2017HC Kerala23 Jun 2021

Bench: HONOURABLE MR.JUSTICE S.V.BHATTI,HONOURABLE MR. JUSTICE BECHU KURIAN THOMAS

Section 143(2)Section 260A

transferred represents commission etc., therefore, TDS should have been deducted and Section 194G is attracted in all fours. Alternatively, in the admitted fact situation of the subject assessment Section 194H is attracted. 7. Advocate Anil Sivaraman invites our attention to the explanation given by the assessee to the notice under Section 143(2) of the Act and contends that from

THE PRINCIPAL COMMISSIONER OF INCOME TAX, KOCHI -I vs. M/S.APOLLO TYRES LTD

ITA/43/2017HC Kerala31 Aug 2021

Bench: HONOURABLE MR.JUSTICE S.V.BHATTI,HONOURABLE MR.JUSTICE VIJU ABRAHAM

For Appellant: THE PRINCIPAL COMMISSIONER OF INCOME TAX, KOCHI -IFor Respondent: M/S.APOLLO TYRES LTD
Section 143(3)Section 144C(5)Section 32(1)(iia)Section 35Section 80Section 92C

deduction u/s 80- IA of the Income Tax Act, 1961? 3. The questions of law raised are similar to the questions of law 1 and 3 raised in ITA No.40 of 2017. So following the reasoning in ITA No.40 of 2017, the questions of law are answered in favour of the assessee and against the revenue. Substantial Question No.2

M/S.APOLLO TYRES LIMITED vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

ITA/23/2017HC Kerala26 Aug 2021

Bench: HONOURABLE MR.JUSTICE S.V.BHATTI,HONOURABLE MR.JUSTICE VIJU ABRAHAM

deduction for the assessment year in question? 3. The learned Counsel appearing for the parties state that the substantial questions of law raised in the instant appeal are similar or identical to substantial question no.(c) in the appeal filed by the assessee in ITA No.249/2015. On 26.08.2021, in ITA No.249/2015, question no.(c) was answered in favour

M/S. APPOLLO TYRES LTD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

ITA/249/2015HC Kerala26 Aug 2021

Bench: HONOURABLE MR.JUSTICE S.V.BHATTI,HONOURABLE MR.JUSTICE VIJU ABRAHAM

Section 40

deduction conforms with Section 43A of the Act. For the above reasons, we answer I.T.A. No. 249/2015 -28- question no.(e) in favour of the assessee and against the Revenue. ITA No.249/2015 is allowed in part as indicated above. The substantial question nos.(a) to (c) are answered in favour of the Revenue, against the assessee, and question

THE PRINCIPAL COMMISSIONER OF INCOME TAX, vs. SMT.GRACY BABU,

ITA/54/2020HC Kerala03 Apr 2024

Bench: HONOURABLE DR. JUSTICE A.K.JAYASANKARAN NAMBIAR,HONOURABLE MR. JUSTICE SYAM KUMAR V.M.

For Respondent: THE PRINCIPAL COMMISSIONER OF INCOME TAX

deduction of tax at source on an amount paid is sufficient to establish that alleged service is rendered, in respect of the amount paid ? (vii) Whether payment made to erstwhile trustees without services actually rendered by them, will fall outside the ambit of Sec.13 ? (viii) Whether mere book addition in the asset side of the balance sheet is sufficient

THE PRINCIPAL COMMISSIONER OF INCOME TAX vs. JOSE THOMAS

ITA/46/2020HC Kerala03 Apr 2024

Bench: HONOURABLE DR. JUSTICE A.K.JAYASANKARAN NAMBIAR,HONOURABLE MR. JUSTICE SYAM KUMAR V.M.

For Respondent: THE PRINCIPAL COMMISSIONER OF INCOME TAX

deduction of tax at source on an amount paid is sufficient to establish that alleged service is rendered, in respect of the amount paid ? (vii) Whether payment made to erstwhile trustees without services actually rendered by them, will fall outside the ambit of Sec.13 ? (viii) Whether mere book addition in the asset side of the balance sheet is sufficient

THE PRINCIPAL COMMISSIONER OF INCOME TAX vs. REENA JOSE

ITA/47/2020HC Kerala03 Apr 2024

Bench: HONOURABLE DR. JUSTICE A.K.JAYASANKARAN NAMBIAR,HONOURABLE MR. JUSTICE SYAM KUMAR V.M.

For Respondent: THE PRINCIPAL COMMISSIONER OF INCOME TAX

deduction of tax at source on an amount paid is sufficient to establish that alleged service is rendered, in respect of the amount paid ? (vii) Whether payment made to erstwhile trustees without services actually rendered by them, will fall outside the ambit of Sec.13 ? (viii) Whether mere book addition in the asset side of the balance sheet is sufficient

THE PRINCIPAL COMMISSIONER OF INCOME TAX, vs. GRACY BABU,

ITA/48/2020HC Kerala03 Apr 2024

Bench: HONOURABLE DR. JUSTICE A.K.JAYASANKARAN NAMBIAR,HONOURABLE MR. JUSTICE SYAM KUMAR V.M.

For Respondent: THE PRINCIPAL COMMISSIONER OF INCOME TAX

deduction of tax at source on an amount paid is sufficient to establish that alleged service is rendered, in respect of the amount paid ? (vii) Whether payment made to erstwhile trustees without services actually rendered by them, will fall outside the ambit of Sec.13 ? (viii) Whether mere book addition in the asset side of the balance sheet is sufficient

THE PRINCIPAL COMMISSIONER OF INCOME TAX vs. JOSE THOMAS,

ITA/56/2020HC Kerala03 Apr 2024

Bench: HONOURABLE DR. JUSTICE A.K.JAYASANKARAN NAMBIAR,HONOURABLE MR. JUSTICE SYAM KUMAR V.M.

For Respondent: THE PRINCIPAL COMMISSIONER OF INCOME TAX

deduction of tax at source on an amount paid is sufficient to establish that alleged service is rendered, in respect of the amount paid ? (vii) Whether payment made to erstwhile trustees without services actually rendered by them, will fall outside the ambit of Sec.13 ? (viii) Whether mere book addition in the asset side of the balance sheet is sufficient