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11 results for “transfer pricing”+ Section 6(1)clear

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Key Topics

Section 143(3)8Section 144C6Section 36(1)(iii)4Section 92C3Section 2633Disallowance3Addition to Income3Deduction3Section 402

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

Section 260A2
Section 143(2)2
Transfer Pricing2

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. 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

1) Sri.Babu P. Thomas, his wife Smt.Gracy Babu and their two major sons. (2) Sri.Jose Thomas, his wife Smt.Reena Jose and their major son and daughter. (3) Sri.P.J.Paulose, his wife Smt.Lizzy Paulose and their two major daughters. Due to difficulties in managing the College, and also due to the personal differences, the trustees decided to discontinue the business and entered

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

1) Sri.Babu P. Thomas, his wife Smt.Gracy Babu and their two major sons. (2) Sri.Jose Thomas, his wife Smt.Reena Jose and their major son and daughter. (3) Sri.P.J.Paulose, his wife Smt.Lizzy Paulose and their two major daughters. Due to difficulties in managing the College, and also due to the personal differences, the trustees decided to discontinue the business and entered

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

1) Sri.Babu P. Thomas, his wife Smt.Gracy Babu and their two major sons. (2) Sri.Jose Thomas, his wife Smt.Reena Jose and their major son and daughter. (3) Sri.P.J.Paulose, his wife Smt.Lizzy Paulose and their two major daughters. Due to difficulties in managing the College, and also due to the personal differences, the trustees decided to discontinue the business and entered

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

1) Sri.Babu P. Thomas, his wife Smt.Gracy Babu and their two major sons. (2) Sri.Jose Thomas, his wife Smt.Reena Jose and their major son and daughter. (3) Sri.P.J.Paulose, his wife Smt.Lizzy Paulose and their two major daughters. Due to difficulties in managing the College, and also due to the personal differences, the trustees decided to discontinue the business and entered

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

1) Sri.Babu P. Thomas, his wife Smt.Gracy Babu and their two major sons. (2) Sri.Jose Thomas, his wife Smt.Reena Jose and their major son and daughter. (3) Sri.P.J.Paulose, his wife Smt.Lizzy Paulose and their two major daughters. Due to difficulties in managing the College, and also due to the personal differences, the trustees decided to discontinue the business and entered

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

6. Mr Joseph Markos appearing for the assessee tried to convince this Court to take a different view by the very same argument put forward by the assessee before the Tribunal and the Assessing Officer. We have two difficulties in appreciating the argument of the assessee to accept the provision made towards commission payable to the agents through whom sales

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

6. We have heard the learned counsel appearing for the parties and also perused the record. At the outset, we make it clear that in the case on hand we are not examining the scope and applicability of Section 263 vis-a-vis a final assessment order made pursuant to directions of DRP, under Section 144C read with Section

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

1) Whether the land was classified in the revenue records as agricultural and whether it was subject to the payment of land revenue? 8 139 ITR 628 I.T.A. No.179/2014 -18- (2) Whether the land was actually or ordinarily used for agricultural purposes at or about the relevant time? (3) Whether such user of the land was for a long period

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

1. Whether, on the facts and in the circumstances of the case- i) The payment made by the assessee to the Sub-agents fall within the clutches of Section 194G/194H of the Income Tax Act? ii) The provisions of section 40(a)(ia) are attracted to the above payments? 2. Did not the Tribunal err in deleting the disallowance made