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10 results for “transfer pricing”+ Section 11(4)clear

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Key Topics

Section 144C5Section 143(3)5Section 2633Deduction3Section 402Section 260A2Section 143(2)2Section 2(14)2Section 352Disallowance

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
Addition to Income2

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

4. Assessments were completed under Section 143(3) read with Section 153A for the assessment years 2003-04 to 2008-09 and I.T.A.Noa.48, 46, 47, 49, 51, 54, 55, 56 & 68/20 & 6/21 :: 16 :: under Section 143(3) for the assessment year 2009-10 in relation to the persons who were searched, namely, Gracy Babu, Jose Thomas and P.J. Paulose

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

4. Assessments were completed under Section 143(3) read with Section 153A for the assessment years 2003-04 to 2008-09 and I.T.A.Noa.48, 46, 47, 49, 51, 54, 55, 56 & 68/20 & 6/21 :: 16 :: under Section 143(3) for the assessment year 2009-10 in relation to the persons who were searched, namely, Gracy Babu, Jose Thomas and P.J. Paulose

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

4. Assessments were completed under Section 143(3) read with Section 153A for the assessment years 2003-04 to 2008-09 and I.T.A.Noa.48, 46, 47, 49, 51, 54, 55, 56 & 68/20 & 6/21 :: 16 :: under Section 143(3) for the assessment year 2009-10 in relation to the persons who were searched, namely, Gracy Babu, Jose Thomas and P.J. Paulose

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

4. Assessments were completed under Section 143(3) read with Section 153A for the assessment years 2003-04 to 2008-09 and I.T.A.Noa.48, 46, 47, 49, 51, 54, 55, 56 & 68/20 & 6/21 :: 16 :: under Section 143(3) for the assessment year 2009-10 in relation to the persons who were searched, namely, Gracy Babu, Jose Thomas and P.J. Paulose

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

4. Assessments were completed under Section 143(3) read with Section 153A for the assessment years 2003-04 to 2008-09 and I.T.A.Noa.48, 46, 47, 49, 51, 54, 55, 56 & 68/20 & 6/21 :: 16 :: under Section 143(3) for the assessment year 2009-10 in relation to the persons who were searched, namely, Gracy Babu, Jose Thomas and P.J. Paulose

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

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 65 of the Bombay Land Revenue Code was obtained for the non-agricultural use of the land? If so, when and by whom (the vendor or the vendee

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

ITA/36/2017HC Kerala04 Aug 2021

Bench: This Court. The Issues Canvassed In The Appeal Relate To Assessment Year 2010-11. Prefaced In The Beginning, The Issues Raised By The Revenue Arise Under Section 144C Read With Section 143(3) Vis-A-Vis Section 263 Of The Income Tax Act, 1961 (For Short 'The Act').

Section 143(3)Section 144CSection 263Section 35Section 40

4. Learned Standing Counsel Sri.Christopher Abraham argues that the Tribunal had committed a fundamental error in law in interdicting the order dated 23.03.2016 made by the Commissioner under Section 263 of the Act. The Tribunal failed to appreciate that Annexure-B order dated 28.03.2014 is a draft assessment order made under Section 144C of the Act. The character or nature

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

4. The learned Counsel appearing for the assessee and the Revenue would state that the questions covered by (a) and (b) are similar to the questions raised by the assessee for the Assessment Year 2003-04 in ITA No.26/2013. This Court vide order dated 29.07.2021 has answered the said questions against the assessee and in favour of the Revenue

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

4. One T Murugan was the Proprietor of M/s.Meenakshy Lucky Centre/a proprietory concern doing I.T.A. Nos. 18, 13 & 29/2017 -6- business as a wholesale dealer of lottery tickets. The assessee was engaged in the said business as Stockist for the sale of lottery tickets of various government/quasi-government agencies and State governments. The assessee purchases lottery tickets from the agencies referred