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4 results for “transfer pricing”+ Section 55clear

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Section 1662

BARUNEI ROLLER FLOUR MILL (P) LTD. vs. COMMISSIONER OF INCOME TAX (APPEALS) 1

In the result, the award of the maximum uniform rate for the

ITA/1/2022HC Orissa03 Nov 2023

Bench: DR. JUSTICE B.R.SARANGI (ACJ),MR. JUSTICE MURAHARI SRI RAMAN

Section 54 of the Transfer of Property Act, to advance the argument that the price component in a sale is an intrinsic and integral part of the transaction and a sale cannot exist without the price component and the price component in a sale transaction cannot be independent, whereas for a ‘collateral purpose’ it should be something i.e. independent

PRINCIPAL COMMISSIONER OF INCOME TAX vs. M/S.AHINSA VINIMAY PVT.LTD.

ITA/132/2018HC Orissa05 Apr 2022

Bench: DR. JUSTICE S. MURALIDHAR (CJ),MR. JUSTICE R.K.PATTANAIK

Section 260

55. A substantial quantum of international trade and transactions depends upon the fair and quick judicial dispensation in such cases. Had it been a case of substantial question of interpretation of Date of Judgment 30-08-2018, ITA No.132/2018 Pr. Commissioner of Income Tax-5 & Another Vs. M/s Novo Nordisk India Pvt. Ltd., 9/11 provisions of Double Taxation Avoidance Treaties

MAHESWAR PANDA vs. I.T.O., WARD-2(1)

ITA/48/2023HC Orissa15 Apr 2024

Bench: DR. JUSTICE B.R.SARANGI,MR. JUSTICE GOURISHANKAR SATAPATHY

Section 166

transferring the burden of paying the amount of compensation from respondent no.1-Insurance Company to the appellants herein.” 27. In the present matter, it is not the case that the victim himself was sitting on the mudguard of the tractor, rather he was sitting in the trolley which was used for the agricultural purpose as they were carrying the rice straw

M/S.SHEETAL REAL vs. INCOME TAX OFFICER

In the result, the appeal fails and the substantial questions of law

ITA/83/2010HC Orissa08 Feb 2022

Bench: DR. JUSTICE S. MURALIDHAR (CJ),MR. JUSTICE R.K.PATTANAIK

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 260ASection 372A

price during this period was phenomenal and none of the companies have declared any dividend. The CIT(A) drew adverse inference against the assessee noting the volume and frequency of the transactions. The CIT(A) came to the conclusion that the assessee was actually engaged actively in share transactions, they had a full-fledged shares Department