M/S.R.S.RANGADAS vs. THE ASST.COMMISSIONER OF INCOME TAX

Appeals are disposed of, with no order as to costs

Bench: C.V. BHASKAR REDDY,UJJAL BHUYAN

price which in fact was not received. Reference can be also made to Commissioner of Income Tax, Bombay versus M/s Godavari Corporation Limited, [1993] 200 ITR 567 (SC) and judgments of this Court in CIT versus Dinesh Jain, HUF, [2013] 352 ITR 629 (Del) and Commissioner of Income Tax versus Late Sh. Gulshan Kumar (Decd.) through

M/S VAIBHAV vs. JOINT COMM. OF INCOME TAX RANGE 3 HYD

Appeal is allowed and the judgments and decrees passed by the

Bench: The Learned Trial Court) Was Allowed & The Judgment & Decree Dated 12.12.2000, Passed By Learned Senior Sub Judge, Kullu Was Set-Aside. (Parties Shall Hereinafter Be Referred To In

Income-tax V. Motor and General Stores (P.) Ltd., AIR 1967 SC 200 (sic), though 'price' is not defined in the Act, it is used in the same sense as in the Sale of Goods Act, 1930 (in short, the 'Sale Act'), and means the money consideration for the sale of goods. The presence of a money consideration

PRINICIPAL COMMISSIONER OF INCOME TAX-7, HYD vs. M/S. DECCAN GRAMEENA BANK, HYD

Appeals are dismissed on withdrawal

Bench: C.V. BHASKAR REDDY,UJJAL BHUYAN

Additional Commissioner of lncome Tax (Transfer Pricing), 6th floor, B Block, lT Towers, A.C. Guards, Hyderabad, in PAN No.AAACF2723N dated 28.0'1.2013 preferred against the Order of the Deputy Commissioner of lncome Tax, Circle 1 (2), Hyderabad PANiGIR No. AAACF2723N dated 21.01 .2O14. (Appeals)-1, Hyderab, rd, Appeal No.0134/ClT (A)-llHyd/2O13 '14, 2015-16 dated 17.02.2016 preferred rgainst the Order

THE PRINCIPAL COMMISSIONER OF INCOME TAX, HYD vs. M/S CONEXANT SYSTEMS PRIVATE LTD., HYD

Appeals are dismissed on withdrawal

Bench: C.V. BHASKAR REDDY,UJJAL BHUYAN

Additional Commissioner of lncome Tax (Transfer Pricing), 6th floor, B Block, lT Towers, A.C. Guards, Hyderabad, in PAN No.AAACF2723N dated 28.0'1.2013 preferred against the Order of the Deputy Commissioner of lncome Tax, Circle 1 (2), Hyderabad PANiGIR No. AAACF2723N dated 21.01 .2O14. (Appeals)-1, Hyderab, rd, Appeal No.0134/ClT (A)-llHyd/2O13 '14, 2015-16 dated 17.02.2016 preferred rgainst the Order

PRINCIPAL COMMISSIONER OF INCOME TAX-7, HYD vs. M/S. DECCAN GRAMEENA BANK, HYD

Appeals are dismissed on withdrawal

Bench: C.V. BHASKAR REDDY,UJJAL BHUYAN

Additional Commissioner of lncome Tax (Transfer Pricing), 6th floor, B Block, lT Towers, A.C. Guards, Hyderabad, in PAN No.AAACF2723N dated 28.0'1.2013 preferred against the Order of the Deputy Commissioner of lncome Tax, Circle 1 (2), Hyderabad PANiGIR No. AAACF2723N dated 21.01 .2O14. (Appeals)-1, Hyderab, rd, Appeal No.0134/ClT (A)-llHyd/2O13 '14, 2015-16 dated 17.02.2016 preferred rgainst the Order

THE PRINCIPAL COMISSIONER OF INCOME TAX-I vs. M/S.CELON LABORATOERIES PVT LTD

Appeals are dismissed on withdrawal

Bench: C.V. BHASKAR REDDY,UJJAL BHUYAN

Additional Commissioner of lncome Tax (Transfer Pricing), 6th floor, B Block, lT Towers, A.C. Guards, Hyderabad, in PAN No.AAACF2723N dated 28.0'1.2013 preferred against the Order of the Deputy Commissioner of lncome Tax, Circle 1 (2), Hyderabad PANiGIR No. AAACF2723N dated 21.01 .2O14. (Appeals)-1, Hyderab, rd, Appeal No.0134/ClT (A)-llHyd/2O13 '14, 2015-16 dated 17.02.2016 preferred rgainst the Order

The Commissioner of income Tax-III, vs. M/S Raj Breeders and Hatcheries [Pvt.] Ltd.,

In the result, we do not find any merit in this appeal

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Income Tax Act, 1961 was admitted by a Bench of this Court vide order dated 05.04.2011 on the following substantial questions of law: i) Whether the stocks transferred on cost price can be assessed to tax on a notional price? ii) Whether the assessee has the right to fix the price of the stock and transfer the same

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

Bench: RAMESH RANGANATHAN,KONGARA VIJAYA LAKSHMI

transferred outside India and the payments were also received outside India. It was pointed out that several activities relating to marketing and sales took place in India. Expatriates from GEII along with employees of GEIIPL constituting the Indian team were mostly involved and participated in the negotiation of prices. These price negotiations took place in India. The Indian customers discussed

The Pr. Commissioner of Income-tax vs. D.L.V. Sridhar

Bench: D.V.S.S.SOMAYAJULU,RAMESH RANGANATHAN

Transfer Pricing Officer had not verified whether the expenditure claimed was correct. Recording the aforesaid findings, the Assessing Officer disallowed the entire claim of Rs.1,48,89,090/- under section 10A of the Act. 5. The aforesaid addition was deleted by the Commissioner of Income

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

Bench: CHALLA KODANDA RAM,G.CHANDRAIAH

addition to technology already transferred is illustrative that it was not a case of complete or full transfer, but only a case of right to use or permission to use the technology by HCL. Thus, the provision for upgradation. The stipulation also reflects acceptance and recognition that the technology in the said field was transient and transitory and not lasting

COMMISSIONER OF INCOME TAX-II vs. M/S IJM (INDIA) INFRASTRUCTURE LIMITED

Appeal is dismissed as withdrawn

Bench: T.VINOD KUMAR,M.S.RAMACHANDRA RAO

INCOME TAX TRIBUNAL APPEAL NO: 595 OF 2014 (lncome Tax Tribunal Appeal Under Section 260 A of the lncome Tax Act 1961, against the order of the lncome Tax Appellate Tribunal, Hyderabad Bench 'A', Hyderabad in lTA.No.43/11yd12014 for assessment Year 200S -2010 dated 29-04-2014 preferred against the Order of the Additional Commissioner of lncome Tax ( Transfer Pricing

THE PRL COMMISSIONER OF INCOME TAX vs. M/S. AUTOMATIC DATA SOLUTIONS AND TECHNOLOGY

Bench: SUREPALLI NANDA,UJJAL BHUYAN

INCOME TAX TRIBUN AL APPEAL NO: 670 OF 2017 lncome Tax Tribunal Appeal Under Section 260-A of the lncome Tax Act, 1961 against the order of the lncome Tax Appellate Tribunal, Hyderabad Bench 'A', Hyderabad in lTA.No.433/Hydl2015 for assessment year 2010-1 1 dated 28.02.2017 preferred against the order of the Additional Commissioner of lncome Tax (Transfer Pricing

THE PRINCIPAL COMM. OF INCOME TAX-1, HYDERABAD vs. M/S ADP PVT. LTD., HYDERABAD

Appeal is dismissed on withdrawal

Bench: SUREPALLI NANDA,UJJAL BHUYAN

Additional Commissioner of lncome Tax (Transfer Pricing), Hyderabad PAN/GIR No.AAACW2655C dated 30.10.2009. Between: The Principal Commissioner of lncome Tax-|, Hyderabad. M/s. ADP P\i,t. Ltd.,6-3-1091/C/1 , Fortune 9, Raj Bhavan Road , Hyderabad- 500082. ...RESPONDENT Counsel for the Appellant: SRI B. NARASIMHA SARM Counsel forthe Respondent: NONE APPEARED The Court made the following: ORDER 1 AND INCOME

THE PRINCIPAL COMMISSIONER OF INCOME TAX-1 vs. M/S. ADP PVT.LTD.,

Bench: SUREPALLI NANDA,UJJAL BHUYAN

INCOME TAX TRIBUNAL APPEAL NO: 632 OF 2016 lncome Tax Tribunal Appeal Under Section 206-A of the lncome Tax Act, '1961 against the order of the lncome Tax Appellant Tribunal, Hyderabad Bench 'B', Hyderabad in lTA.No.171 1/Hydl2011 for Assessment Year 2007-08 dated 23.12.2015 preferred against the Order of the Additional Commissioner of lncome Tax (Transfer Pricing

Commissioner of Income Tax (TDS), vs. M/s. Vipanchi Chit Fund Ltd.,

The appeal is dismissed

Bench: P.SAM KOSHY,NARSING RAO NANDIKONDA

price) to tax in this assessment year, i.e., assessment year 2006-07. ITA 569/2012 Page 3 of 6 4. Consequently, the Assessing Officer made an addition of ` 16,93,42,000/- on this account. The said addition was deleted by the Commissioner of Income Tax (Appeals) and the deletion was confirmed by the Tribunal by virtue of the impugned order

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

transfer pricing adjustment in the hands of Nortel India. 61. Thus, in our view, the question whether the Assessee has a PE in India is not material as it is not possible to hold that any part of the income of the Assessee could be apportioned to operations carried on in India. 62. Having stated the above, for the sake

The Pr. Commissioner of Income Tax-2 vs. M/s. GJ Trading Pvt Ltd

Bench: C.V. BHASKAR REDDY,UJJAL BHUYAN

Transfer Pricing Study: - 1 FTS 2 FIS 3 Act 4 DTAA 5 Tribunal Digitally Signed By:KAMLESH KUMAR Signing Date:17.02.2025 14:23:05 Signature Not Verified ITA 202/2022 & Connected Matters Page 7 of 22 “d) Technical Knowledge: Customs brokerage and other services involves providing services at destination, such as helping customers clear shipments through customs by preparing required documentation

Comissioner of Income Tax, vs. P. Ramakrishna Prasad (HUF),

In the result, the appeal is partly allowed

addition to his salary he had the benefit of rent free quarters and a Car for his use and he was an assessee under Central Income Tax Act and assessed by Salary Circle-Eranakulam. From out of his savings he had not only discharged the said balance of price but also subsequently having served in the said Company which