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77 results for “transfer pricing”+ Business Incomeclear

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Key Topics

Section 26036Section 8032Section 260A29Section 10A26Deduction19Addition to Income18Comparables/TP16Transfer Pricing11Section 10(20)

Principal Commissioner of Income Tax-3 vs. M/s Satyasai Bhavani Hsopitals Private Limited

ITTA/537/2015HC Telangana02 Nov 2015

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Section 260

Transfer Pricing/ determination of the ‘Arm’s Length Price’; [II] The Scheme of procedure of assessment and appeals to the Tribunal and High Court/Supreme Court. [III] The scope of interference by High Court under Section 260-A of the Act in these type of cases. Findings of the Tribunal: 12. We find it appropriate to quote some portions

The Commissioner of Income Tax-IV vs. M/s Pokarna Limited

The appeals are dismissed

ITTA/273/2012HC Telangana18 Feb 2025

Bench: P.SAM KOSHY,NARSING RAO NANDIKONDA

Section 260A

income under the head `Business’ and allow the claim of expenditures made thereon by the assessee. Insofar as the Capital gains on the sale of land to one of its sister concerns namely M/s.MD Properties Pvt. Ltd., is concerned, relying on Section 50C of the Act providing for adoption of the guideline value as the consideration for transfer

Showing 1–20 of 77 · Page 1 of 4

10
Section 80H9
Section 80P(2)(a)8
Section 143(3)8

Commissioner of Income Tax -II vs. The Agrasen Coop. Urban Bank Ltd.,

In the result, for the above reasons, these appeals fail and

ITTA/711/2006HC Telangana07 Jun 2011

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

Section 260ASection 46Section 80P(2)(a)

income derived from voluntary non-statutory deposits would not be eligible for deduction is illogical and cannot be sustained. As a matter of fact, in all these cases, a finding was recorded that the RCS issued necessary permission to the assesses to use the surplus reserve fund for the banking business. Assuming that there is no such sanction

The Commissioner of Income Tax-II vs. The Andhra Bank Employees Co.Operative Bank Limited

In the result, for the above reasons, these appeals fail and

ITTA/243/2007HC Telangana07 Jun 2011

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

Section 260ASection 46Section 80P(2)(a)

income derived from voluntary non-statutory deposits would not be eligible for deduction is illogical and cannot be sustained. As a matter of fact, in all these cases, a finding was recorded that the RCS issued necessary permission to the assesses to use the surplus reserve fund for the banking business. Assuming that there is no such sanction

COMMISSIONER OF INCOME TAX-II, HYDERABAD vs. M/s. The A.P.Vardhaman(Mahila)Cooperative Urban

In the result, for the above reasons, these appeals fail and

ITTA/715/2006HC Telangana07 Jun 2011

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

Section 260ASection 46Section 80P(2)(a)

income derived from voluntary non-statutory deposits would not be eligible for deduction is illogical and cannot be sustained. As a matter of fact, in all these cases, a finding was recorded that the RCS issued necessary permission to the assesses to use the surplus reserve fund for the banking business. Assuming that there is no such sanction

Commissioner of Income Tax-II, vs. M/S The A.P.Mahesh Coop. Urban Bank Ltd,

In the result, for the above reasons, these appeals fail and

ITTA/718/2006HC Telangana07 Jun 2011

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

Section 260ASection 46Section 80P(2)(a)

income derived from voluntary non-statutory deposits would not be eligible for deduction is illogical and cannot be sustained. As a matter of fact, in all these cases, a finding was recorded that the RCS issued necessary permission to the assesses to use the surplus reserve fund for the banking business. Assuming that there is no such sanction

THE COMMISSIONER OF INCOME TAX III, vs. M/S. SAVIJANA SEA FOODS PVT. LTD.,

Appeals of the Revenue are dismissed

ITTA/55/2010HC Telangana20 Dec 2024

Bench: J SREENIVAS RAO,ALOK ARADHE

Section 260

price of the jewellery stolen in a robbery or a burglary was therefore expenditure for the purpose of the business. There can be no doubt that the expenditure was wholly and exclusively in the interest of the business. The expenditure was laid out for no other purpose.” 33. Applying the law explained by the Supreme Court in the above decisions

Commissioner of Income Tax, vs. M/s. Kokivenkateswara Reddy AND others,

Appeals of the Revenue are dismissed

ITTA/210/2003HC Telangana21 Jun 2011

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

Section 260

price of the jewellery stolen in a robbery or a burglary was therefore expenditure for the purpose of the business. There can be no doubt that the expenditure was wholly and exclusively in the interest of the business. The expenditure was laid out for no other purpose.” 33. Applying the law explained by the Supreme Court in the above decisions

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

transfer of the assets. This decision of the CIT (A) has been upheld by the ITAT also dismissing the appeal of the Revenue vide impugned order dated 19th December, 2009. The ITAT downrightly observed that assessee seems to be the elite owner of the Trademark & Copyright of these publications. Also publications i.e. journals were undeniably capital assets of the assesee

M.Y.Maharshi vs. The Asst. Commissioner of Income-Tax

In the result, we do not find

ITTA/282/2013HC Telangana16 Jul 2013
Section 10ASection 143(1)Section 143(2)Section 260Section 92C

business of research and development in the area of material sciences and process technology and providing and related software development services. The assessee filed return of income for the Assessment Year 2006-07 on 31.10.2006 and declared an income of Rs.2,12,18,961/-. The return of income was processed under Section 143(1) on 10.09.2007. Subsequently, the case

COMMISSIONER OF INCOME TAX vs. M/S K.VENKATESWARA RAO

ITTA/188/2003HC Telangana21 Jun 2011

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

Section 143(3)Section 80Section 80H

income, the report of such audit in the prescribed form duly signed and verified by such accountant. 1 (6) Where any goods held for the purposes of the business of the industrial under- taking or the hotel are transferred to any other business carried on by the assessee, or where any goods held for the purposes of any other business

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

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

transfer of a capital asset situate in India: [Explanation 1] –For the purposes of this clause—(a) in the case of a business of which all the operations are not carried out in India, the income of the business deemed under this clause to accrue or arise in India shall be only such part of the income as is reasonably

THE PRL COMMISSIONER OF INCOME TAX-II, VISAKHAPATNAM vs. L SURYAKANTHAM, VISAKHAPATNAM

In the result, the appeal fails and is hereby dismissed

ITTA/285/2017HC Telangana08 Oct 2018

Bench: RAMESH RANGANATHAN,KONGARA VIJAYA LAKSHMI

Section 143(2)Section 14ASection 260Section 80JSection 92C

INCOME TAX- CENTRAL Vs. VEER GEMS' (2018) 256 TAXMAN 298 (SC). Therefore, both the provisions namely sub-Sections (1) and (2) have to be read together. It is also pointed out from the order passed by the Dispute Resolution Panel that the panel itself has recorded a finding that the Transfer Pricing Officer has gone into the provision of Section

THE COMMISSIONER OF INCOME TAX, VIJAYAWADA vs. M/S. PADMAVATHI MANSION (P) LTD., VIJAYAWADA

ITTA/700/2017HC Telangana21 Nov 2017

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

Section 10ASection 260Section 260A

Transfer Pricing Adjustments’ made by the concerned authorities below. We consider it appropriate to quote Date of Judgment 05-07-2018 I.T.A.No 700/2017. The Pr. Commissioner of Income-Tax, CIT (A) & Anr. Vs. M/s. Global E-Business

INCOME TAX BANGALORE vs. SHALINI BHUPAL

Appeal is dismissed

ITTA/38/2000HC Telangana20 Jun 2013
Section 260Section 80Section 80HSection 80ISection 80J

income, the report of such audit in the prescribed form duly signed and verified by such accountant. (8) Where any goods held for the purposes of the business of the industrial undertaking or the hotel or the operation of the ship [or the business of repairs to ocean-going vessels or other powered craft] are transferred to any other business

Principal Commissioner of Income Tax-3, vs. M/s Novus GBS Private Limited,

ITTA/542/2015HC Telangana02 Nov 2015

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Section 10ASection 260Section 260A

business income of the undertaking eligible for deduction under Section 10A of the Act, Consequently, grounds S.No.1 raised by the assessee is allowed.” 4. The controversy involved herein is no more res integra in view of the decision of this Court in I.T.A. Nos.536/2015 c/w 537/2015 dated 25.06.2018 [Prl. Commissioner of Income Tax & Anr. V/s. M/s.Softbrands India

J Anjaneya Sharma vs. Commissioner of Income Tax-V

ITTA/508/2013HC Telangana25 Oct 2013
Section 260Section 92A

Transfer of Shares in Tax Havens (like in the case of Vodafone etc.), if based on relevant facts, such substantial questions of law could be raised before the High Court under Section 260-A of the Act, the Courts could have embarked upon such exercise of framing and answering such substantial question of law. On the other hand, the appeals

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

business activity. GEIIPL is an India incorporated company and is party to the Global Service Agreement (GSA) with GEIOC, for providing limited market support services to GE and its affiliates (including GEPI.). In exchange, it was remunerated on a cost-plus basis. It was assessed to income tax and also subjected to arms‟ length price (ALP) determination by a Transfer

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

ITTA/365/2018HC Telangana22 Oct 2018

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

Section 10Section 10ASection 115Section 260

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 Tax (Appeals), who observed that the respondent-assessee was maintaining separate accounts for STPI

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

ITTA/13/2008HC Telangana23 Mar 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Section 260

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