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10 results for “transfer pricing”+ Section 10(3)clear

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Key Topics

Section 143(2)3Deduction3Section 260A2Section 2(14)2Section 92C2Section 143(3)2Addition to Income2Disallowance2

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

10 I.T.A.No.6/2021 M/s.Carmel Educational Trust 2010-11 I.T.A.No.310/2019 2. The brief facts necessary for disposal of these appeals are as follows: The Carmel Educational Trust, Adoor was constituted by a registered trust deed dated 14.08.2001. It is engaged in running educational institutions imparting education in the subjects of Engineering and Management. The 12 trustees of the Trust belong

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

10 I.T.A.No.6/2021 M/s.Carmel Educational Trust 2010-11 I.T.A.No.310/2019 2. The brief facts necessary for disposal of these appeals are as follows: The Carmel Educational Trust, Adoor was constituted by a registered trust deed dated 14.08.2001. It is engaged in running educational institutions imparting education in the subjects of Engineering and Management. The 12 trustees of the Trust belong

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

10 I.T.A.No.6/2021 M/s.Carmel Educational Trust 2010-11 I.T.A.No.310/2019 2. The brief facts necessary for disposal of these appeals are as follows: The Carmel Educational Trust, Adoor was constituted by a registered trust deed dated 14.08.2001. It is engaged in running educational institutions imparting education in the subjects of Engineering and Management. The 12 trustees of the Trust belong

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

10 I.T.A.No.6/2021 M/s.Carmel Educational Trust 2010-11 I.T.A.No.310/2019 2. The brief facts necessary for disposal of these appeals are as follows: The Carmel Educational Trust, Adoor was constituted by a registered trust deed dated 14.08.2001. It is engaged in running educational institutions imparting education in the subjects of Engineering and Management. The 12 trustees of the Trust belong

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

10 I.T.A.No.6/2021 M/s.Carmel Educational Trust 2010-11 I.T.A.No.310/2019 2. The brief facts necessary for disposal of these appeals are as follows: The Carmel Educational Trust, Adoor was constituted by a registered trust deed dated 14.08.2001. It is engaged in running educational institutions imparting education in the subjects of Engineering and Management. The 12 trustees of the Trust belong

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

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

3 (2010) 322 ITR 180 (SC) I.T.A. No. 249/2015 -22- Woodward's case [2009] 312 ITR 254, the court observed thus (page 272): "... what triggers the adjustment in the actual cost of the assets, in terms of the unamended section 43A of the 1961 Act is the change in the rate of exchange subsequent to the acquisition of asset

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

price. The assessee acts as a post-office. There is no relationship of Principal and Agent between the assessee and his retail buyers. The retail sellers did not provide service to the assessee thus entitling for receipt of commission/incentive from the assessee. He places strong reliance on Section 194G of the Act and argues that the basic ingredients warranting application

THE COMMISSIONER OF INCOME TAX-1, KOCHI vs. M/S.COCHIN MALABAR ESTATES & INDUSTRIES LTD.

ITA/179/2014HC Kerala28 Oct 2021

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

Section 143(2)Section 2(14)Section 2(14)(iii)Section 260A

3) Whether such user of the land was for a long period or whether it was of a temporary character or by way of a stop- gap arrangement? (4) Whether the income derived from the agricultural operations carried on in the land bore any rational proportion to the investment made in purchasing the land? (5) Whether, the permission under Section

SHRI JOSEPH THANNIKOTTU KORAH vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX,

ITA/310/2019HC Kerala25 Mar 2022

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

Section 143(2)

transferred 76.73 ares of land to one Sri Sajiv ITA NO. 310 OF 2019 -3- Mathai for a total consideration of Rs.3,35,700/-. The assessee produced the sale deed dated 20.1.2011. The case of the assessee is that though the document value is only Rs.3,35,700/-, the actual consideration was for Rs.31,00,000/- including an advance