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28 results for “transfer pricing”+ Section 100clear

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Key Topics

Section 26010Section 10(20)10Section 260A8Addition to Income8Section 12A6Section 8O6Section 9(1)(vi)5Deduction5Section 10(29)

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 Adjustments’ should be allowed to become final with a quietus at the hands of the final fact finding body, i.e. the Tribunal. Comparative Analysis of Section 260-A of Income Tax Act, 1961 and Sections 100

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

Appeals are disposed of, with no order as to costs

ITTA/406/2005HC Telangana19 Oct 2022

Bench: C.V. BHASKAR REDDY,UJJAL BHUYAN

Section 2(47)Section 271(1)(c)

Showing 1–20 of 28 · Page 1 of 2

4
Section 10A4
Exemption4
Disallowance2
Section 45(1)
Section 48
Section 54F

price of each share of NIIT as Rs.1,493/-, instead of Rs.500/- per share. 11. Appeals filed by the assessee were dismissed by the Commissioner of Income Tax (Appeals) vide orders dated 13th March, 2002. 12. Tribunal by common order dated 29th January, 2004 has dismissed the second appeals filed by the assessee. Tribunal in the impugned order has referred

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

Appeal is allowed and the judgments and decrees passed by the

ITTA/58/2002HC Telangana14 Sept 2022

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

For Appellant: Mr. Bimal Gupta, Sr. Advocate with

transfer by sale in regard to immovable property of the value of ₹ 100 or more and that is by a registered instrument. 17. It is now well settled that payment of the entire price is not a condition precedent for completion of the sale by passing of title, as Section

Commissioner of Income Tax vs. Sri Chirla Rama Reddy, Contract

Appeal is dismissed with costs

ITTA/70/2007HC Telangana23 Mar 2016

Bench: The Hon’Ble Mr. Justice N.K.Sudhindrarao R.S.A.No.70/2007

Section 100

100 is to be effected through registered document which invariably supposes that it shall be in writing and 90 sufficient non judicial stamp shall be required. Section 54 of the Transfer of Property Act, reads as under: 54. “Sale” defined.—‘‘Sale” is a transfer of ownership in exchange for a price

The Commissioner of Income Tax-V vs. The Armed Forces Officers Co.Op Housing Society Ltd

ITTA/78/2007HC Telangana27 Aug 2011

Bench: CHALLA KODANDA RAM,G.CHANDRAIAH

transferred has to be known, the price has to be known and if any balance is payable what is that balance due. On such aspects existing then such a document will be a contract under the Indian Contract Act in view of Section 10 of the Indian Contract Act which states that all agreements are contracts if they are entered

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

transfer to other entities. In terms of the application made to RBI and permission obtained, the liaison office was to act as a communication channel between the head office and the customers in India. The assessees did not file returns of income for any year. 5. A survey under Section 133A of the Act was conducted

M\S.CHENNAKESAVA VIJAYAWADA vs. THE COMMISSIONER OF INCOME TAX VIJAYAWAD

The Appeal is dismissed

ITTA/33/2000HC Telangana27 Aug 2012

Bench: GODA RAGHURAM,M.S.RAMACHANDRA RAO

Section 194CSection 197(1)Section 201

100 Crores; Rs. 438 Crores & Rs. 455 Crores respectively. It was noticed by the ITO that these contracts were allotted to its sister concern viz., Messrs. Essar Projects Limited which had obtained a Certificate u/s. 197(1) of the Income Tax Act, 1961 [“Act” for short] for tax deduction at a lower rate on various contract payments to be made

The Commissioner of Income TAx-IV, vs. M/s. Mahaveer Enterprises (India) Limited

The Appeal is dismissed

ITTA/94/2008HC Telangana23 Mar 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Section 21

100. Page 8 of 76 C/LPA/94/2008 JUDGMENT DATED: 06/07/2021 RAVJIBHAI PRABHUDAS PATEL SINCE DECD. THR'HEIRS V/s ADDITIONAL COLLECTOR AND COMPETENT AUTHORITY U.L.C. (4) State of Uttar Pradesh v. Hari Ram, reported in (2013) 4 SCC 280. (5) Mangalsen v. State of U.P., reported in (2013) 4 SCC 332. (6) Vipinchandra Vadilal Bavishi (Dead) by Legal Representatives

Commissioner of Income Tax-III vs. Sri Atluri Subba Rao,

ITTA/110/2013HC Telangana26 Jun 2013
For Respondent: Mr. Surajit Nath Mitra, Sr. Adv
Section 4(3)(b)

price to purchase the suit land, the finding of the learned Trial Judge on this score was absolutely justified but the Appeal Court below, without considering the documents proved by the defendants in support of their said defence, has reversed the judgment and decree of the learned Trial Judge. He further submits that the defence of the defendants squarely comes

PR COMMISSIONER OF INCOME TAX-2, HYDERABAD vs. M/S GOLDEN STAR FACILITIES AND SERVICES PVT LTD., HYD

ITTA/335/2017HC Telangana26 Sept 2018

Bench: RAMESH RANGANATHAN,KONGARA VIJAYA LAKSHMI

Section 13 which provides for Rule making power of the Central Government in respect of minerals. Section 13 subsection (1) WP(C). 11249/2010 & other contd cases. -:88:- and Section 13 Sub-section (2) in so far as relevant in the present case are as follows: “13. Power of Central Government to make Rules in respect of minerals.-- (1) The Central

Principal Commissioner of Income Tax-2 vs. M/s.Viskha Container Terminal Private Limited

ITTA/439/2018HC Telangana08 Oct 2018

Bench: RAMESH RANGANATHAN,KONGARA VIJAYA LAKSHMI

Section 143(2)Section 260Section 268

Pricing Officer (TPO) vide letter dated 30.11.2009 and during the course of proceeding before the TPO, assessee vide its letter dated 09.06.2010 categorically stated that its registered office was at Hyderabad and it stood merged with Wipro Ltd., pursuant to the scheme of amalgamation approved by the High Court of Andhra Pradesh vide order dated 21.02.2008 and scheme of amalgamation

THE COMMISSIONER OF INCOME TAX-IV, HYDERABAD vs. M/S NAVA BHARAT VENTURES LTD., HYDERABAD

ITTA/251/2014HC Telangana18 Jun 2025

Bench: P.SAM KOSHY,NARSING RAO NANDIKONDA

For Respondent: C V NARA
Section 260Section 260ASection 80Section 8O

100% deduction under Se under which the Parties can claim and not for sale of Power to Assessment Order for the Assess 2005-06, the claim of deduction 196 1 was disallowed as assessee under Section 80-IA of the Rs.37,34,55,899 l- in resPect of assessment Year. Further; the As the deduction claimed

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

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

100% Nortel Networks International Finance & Holding BV Nortel Networks India International Inc. (Appellant) 99.82% 99.99% Nortel Networks Singapore Pte. Nortel Networks Mauritius Ltd. 99.99% Nortel Networks India Pvt. Ltd. ITA 666/2014 & Ors. Page 9 of 57 9. The Nortel Canada also has a Liaison Office in India (hereafter called ‗Nortel LO‘). 10. Nortel India negotiated and entered into three contracts

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)

100 Watts before applying it to the transmitting antenna. The latter transforms the electrical signal from all the transponders into an equivalent electromagnetic form for radiation into the footprint where the receiving terminals are located. 8. This is the service the assessees provide to their customers, the income from which is sought to be taxed under Section

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)

100 per cent export oriented undertakings and industrial undertakings in the North Eastern Region. These permit deduction of whole or part of the profits for certain period while computing the total income for the purpose of levy of tax. By the very nature of the benefit conferred, it is for the assessee to discharge the onus by showing that

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)

100 per cent export oriented undertakings and industrial undertakings in the North Eastern Region. These permit deduction of whole or part of the profits for certain period while computing the total income for the purpose of levy of tax. By the very nature of the benefit conferred, it is for the assessee to discharge the onus by showing that

The Commissioner of Income Tax IV vs. M/s. Nava Bharat Ferro Alloys Ltd.,

ITTA/392/2013HC Telangana05 Sept 2013
Section 14Section 14(1)(e)

100 square meters for setting up an appropriate industry here. The petitioner has been paying the installments of the aforesaid plot regularly and this industrial unit is also likely to be commissioned soon. In this case also, when actually setting up the industrial unit here, the petitioner will necessarily have to stay/ live here (to supervise actual execution of works

Commissioner of Income Tax-II vs. Hycons Infrastructure (India) Ltd.

The appeals are dismissed

ITTA/411/2013HC Telangana25 Sept 2013
Section 3Section 3(3)Section 5ASection 5A(1)

100% excise duty was modified and limited to the extent of value additi on with varying rates of exemption of the central excise duty. 4. The respondents, in WA No. 243 of 2009 and WA No. 230 of 2009, aggrieved by the modified notifications, which withdrew the concessions earlier offered i n the previous Industrial Policy and the notifications issued

Commissioner of Income Tax-3, vs. M/s State Bank of Hyderabad

ITTA/77/2016HC Telangana20 Jun 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Section 10ASection 260Section 260A

100% Export Oriented Unit and therefore, the benefit of S.10B should be denied to the Respondent-assessee before this Court. 20. We are unable to accept even this submission of learned counsel for the appellant-Revenue. We do not find any good reason to take a narrow and pedantic approach in construing the words “by an Undertaking” and restricting

The Commissioner of Income Tax (Central) vs. M/s Hyderabad House Pvt Ltd.,

ITTA/250/2013HC Telangana11 Jul 2013

price index for industrial workers [CPI (IW)]. The view in Kamla Devi (supra) was followed in a number of subsequent decisions of this Court in cases reported as Ashwani Gupta v. Government of India & Ors. 117 (2005) DLT 112; Tasleema v. State (NCT of Delhi) & Ors. ILR (2009) 6 Del 486 : (2009) 161 DLT 660 (DB); Nagrik Sangarsh Samiti