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15 results for “capital gains”+ Permanent Establishmentclear

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Key Topics

Section 10(20)10Section 260A7Section 966Section 12A6Section 143(3)5Section 9(1)(vi)5Section 10(29)4Double Taxation/DTAA3Section 4(1)

Commissioner of Income Tax (TDS), vs. M/s Country Club Inda Limited

ITTA/667/2014HC Telangana29 Jan 2015
Section 143(3)Section 147Section 260A

Permanent Establishment (hereafter 'PE') in India and consequently, is chargeable to tax under the Act in respect of its business income attributable to its PE in India. Factual background 8. The Assessee (formerly known as Nortel Networks RIHC Inc) was incorporated as a company on 7th June, 2002 under the laws applicable in the State of Delaware

PR COMMR OF INCOME TAX-2, HYDERABAD vs. K RAVINDER REDDY, HYDERABAD

ITTA/621/2017HC Telangana23 Aug 2018

Bench: RAMESH RANGANATHAN,KONGARA VIJAYA LAKSHMI

Section 260A

establishes that the liaison office is undertaking an activity of trading and therefore entering into business contracts, fixing price for sale of goods and merely because the officials of the liaison office are not signing any written contract would not absolve them from liability. Now that the investigation has revealed the facts, we are sure that the same will

2
Exemption2
Business Income2
Addition to Income2

COMMISSIONER OF INCOME TAX-III, HYD vs. M/S. SUJANA METALS LTD, HYD

ITTA/549/2011HC Telangana21 Apr 2025

Bench: P.SAM KOSHY,NARSING RAO NANDIKONDA

Section 260Section 28

establish that it was a case of sale of capital assets resulting into capital gain:- (a) That the assessee has sold and transferred permanently

COMMISSIONER OF INCOME TAX RAJAHMUNDRY vs. M/S.B.KRISHNA MURTHY KAKINADA AND 2 ORS

ITTA/93/2002HC Telangana10 Dec 2013

Bench: CHALLA KODANDA RAM,G.CHANDRAIAH

Section 260A

permanent establishment, except in the case of a banking institution. 4. It is understood that the deductions in respect of the head office expenses as referred to in paragraph (3) of Article III of the Agreement shall in no case be less than what are allowable under the Indian Income-tax Act as on the date of entry into force

THEE COMMSSR.OF INCOME TAX.HYD. vs. CHALLA SHANKER REDDY.HYD.

ITTA/80/2002HC Telangana13 Dec 2013

Bench: L.NARASIMHA REDDY,T.SUNIL CHOWDARY

Section 96

permanent frirect:rs. The appellant No.1/Image Deve.ope :s filed Form No.23 on 09.10. 1!)96 appointing the appellant No.2/C.V Rao as the Managing Dire(rtor. of the appellant No.l/Image Developers and the said Form No.23 rvr; s registered with the Registrar of Ocmpanies on 14.o2.1997. 29. On 24 .1'. .)993, the appellant No.2/C.V. Rao caused the respondents

COMMR.OF I.T. RAJAHMUNDRY vs. M/S.NARAYANA CHOWDARYAND ORS KAKINADA

ITTA/82/2002HC Telangana10 Dec 2013

Bench: CHALLA KODANDA RAM,G.CHANDRAIAH

Section 96

permanent frirect:rs. The appellant No.1/Image Deve.ope :s filed Form No.23 on 09.10. 1!)96 appointing the appellant No.2/C.V Rao as the Managing Dire(rtor. of the appellant No.l/Image Developers and the said Form No.23 rvr; s registered with the Registrar of Ocmpanies on 14.o2.1997. 29. On 24 .1'. .)993, the appellant No.2/C.V. Rao caused the respondents

The Commissioner of Income Tax, vs. M/s. Laila Impex,

Accordingly answered against the Revenue. The appeals fail and are dismissed, without

ITTA/473/2012HC Telangana09 Jul 2013
Section 143(3)Section 144CSection 260ASection 9(1)(vi)

Capital gains") for— (i) the transfer of all or any rights (including the granting of a licence) in respect of a patent, invention, model, design, secret formula or process or trade mark or similar property ; (ii) the imparting of any information concerning the working of, or the use of, a patent, invention, model, design, secret formula or process or trade

COMMISSIONER OF INCOME TAX - (TDS), vs. M/s. Suman Chit Funds (P) Ltd.,

ITTA/120/2013HC Telangana27 Jun 2013
Section 96

permanent frirect:rs. The appellant No.1/Image Deve.ope :s filed Form No.23 on 09.10. 1!)96 appointing the appellant No.2/C.V Rao as the Managing Dire(rtor. of the appellant No.l/Image Developers and the said Form No.23 rvr; s registered with the Registrar of Ocmpanies on 14.o2.1997. 29. On 24 .1'. .)993, the appellant No.2/C.V. Rao caused the respondents

Commissioner of Income Tax, vs. Agricultural Market Committee,

ITTA/251/2008HC Telangana01 Mar 2011

Bench: V.V.S.RAO,RAMESH RANGANATHAN

For Respondent: Ms. K.Lalitha, Standing Counsel for
Section 10(20)Section 10(29)Section 12ASection 260ASection 4Section 4(1)

gains;] Chapter III contains provisions which deal with incomes which do not form part of total income for the purpose of levy of income tax. As of now, there are fourteen (14) sections. These can be conveniently grouped into four categories. Section 10 enumerates incomes from various sources of various institutions and persons which shall not be included in computing

Commissioner of Income Tax, Guntur. vs. Agricultural Market Committee, Kangiri.

ITTA/318/2008HC Telangana01 Mar 2011

Bench: V.V.S.RAO,RAMESH RANGANATHAN

For Respondent: Ms. K.Lalitha, Standing Counsel for
Section 10(20)Section 10(29)Section 12ASection 260ASection 4Section 4(1)

gains;] Chapter III contains provisions which deal with incomes which do not form part of total income for the purpose of levy of income tax. As of now, there are fourteen (14) sections. These can be conveniently grouped into four categories. Section 10 enumerates incomes from various sources of various institutions and persons which shall not be included in computing

V.C. NANNAPANENI vs. COMMISSIONER OF INCOME TAX,

In the result, the appeals are allowed

ITTA/159/2005HC Telangana05 Jan 2018

Bench: C.V.NAGARJUNA REDDY,T.AMARNATH GOUD

For Appellant: Mr. K. Vasant KumarFor Respondent: Ms. K. Mamata
Section 10(3)Section 143(1)Section 143(3)

Permanent Account/G.I.R. No.N-707/ABEPN 6301 L. The appellant filed his returns of income for the assessment year 1998-99 on 31.10.1998 and for the assessment year 1999- 2000 on 29.9.1999. For the assessment year 1998-99 he declared loss of Rs.1,91,209/- and for the next assessment year he declared loss of Rs.5,21,560/-. The returns of income were

The Commissioner of Income Tax vs. M.Venkata Krishna Mohan

ITTA/325/2005HC Telangana07 Apr 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

established with aid and assistance of foreign country will continue. Since, it is found that the Agreement in question was crucial for setting up of the plant project in question for manufacturing of the goods, the expenditure in the form of royalty paid would be in the nature of capital expenditure and not revenue expenditure. The Tribunal is conclusion that

M/S.HASTALLOY INDIA LTD vs. DY COMMISSIONER OF INCOME TAX/VIZAG

ITTA/22/2000HC Telangana16 Aug 2012

Bench: GODA RAGHURAM,M.S.RAMACHANDRA RAO

permanent staff for maintenance, repairs and providing stipulated facilities by separately charging some nominal fees would not render the monthly rentals from bare letting out of the flats as involving complex activities of the nature of organized business. The case of Narasingh Kar, 113 ITR 712 (OR) referred to by the A.R. was clearly distinguishable on facts since the activities

M/s. Canara Securities Ltd vs. Dy. Commissioner of Income Tax

ITTA/3/2020HC Telangana25 Aug 2020

Bench: M.S.RAMACHANDRA RAO,T.AMARNATH GOUD

establish practice and is also in violation of the principles of natural justice. 31. Mr. Khambatta, learned senior advocate appearing for the appellants elaborated his submissions in the following manner. It is reiterated that the will sought to be probated by the Birla’s contained identical list of properties and in this regard referred to the probate petitions of Shri

M/s Durga Granites, vs. The Assistant Commissioner of Income Tax, Circle - 1,

ITTA/30/2023HC Telangana04 Sept 2023

Bench: P.SAM KOSHY,LAXMI NARAYANA ALISHETTY

Permanent Resident of 4 Andul Raj Road, PO-Southern Market, PS-Kalighat. Kolkata- 700026, West Bengal. ..........Petitioner. -Versus- 1. The State of Jharkhand, through its Secretary, Department of Industries, Mines and Geology, having its office at Yojna Bhawan, P.O. and P.S. Doranda, District Ranchi (Jharkhand), PIN 834 002. 2. The Secretary, Road Construction Department, Government of Jharkhand, having its office