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85 results for “transfer pricing”+ Section 12clear

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Key Topics

Section 26051Addition to Income28Section 8023Section 10A20Section 260A19Deduction15Section 9611Transfer 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

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)

Showing 1–20 of 85 · Page 1 of 5

10
Survey u/s 133A10
Section 80H9
Section 1519
Section 10(29)
Section 12A
Section 260A
Section 4
Section 4(1)

Transfer of Undertakings) Act, 1980 or any other bank being a bank included in Second Schedule to Reserve Bank of India Act, 1934 and the like. The breach of Section 11(5) would attract Section 13(1)(d) of the IT Act and the benefit under Sections 11 and 12 would not be available if funds are deposited or invested

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)

Transfer of Undertakings) Act, 1980 or any other bank being a bank included in Second Schedule to Reserve Bank of India Act, 1934 and the like. The breach of Section 11(5) would attract Section 13(1)(d) of the IT Act and the benefit under Sections 11 and 12 would not be available if funds are deposited or invested

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

Transfer Pricing Officer has not examined the controversy in detail in the earlier years and the determination of arms length price is independent in each of the assessment year and recorded a perverse finding? (3) Whether the Tribunal committed an error in not appreciating the fact that loans or external commercial borrowings between the cross border entities resulting

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

transfer pricing adjustment has to be set aside even when the said company is deemed to be AEs as per Section 92A (2)(g) of the Act as the assessee’s business for A.Y. 2010-11 is only of Jockey Products which is completely dependent on know-how, trade-marks and licenses of Joint International Inc (JII)?’ 12

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)Section 45(1)Section 48Section 54F

Section 54F in respect of purchase of House No.5, Golf Links, New Delhi for Rs.10.75 Crores was allowed and the balance amount of Rs.4,18,00,000/- was treated as long term capital gains. In other words, the Assessing Officer assumed the transfer price of each share of NIIT as Rs.1,493/-, instead of Rs.500/- per share. 11. Appeals filed

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

transferred to the buyer subject to the statutory charge for the unpaid part of the sale price. 25. Thus, the sale deed could not have been invalidated on the reasoning that there was failure of the future consideration. 26. This Court held in Brahama Nand v. Roshani Devi, 1988 SCC OnLine

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

transfer pricing rules, it held the Assessing Authority does not have the power to substitute the value for the actual sale price in the absence of any evidence of understatement of the value. Therefore, the said finding recorded by the Assessing Authority was also set-aside and the appeal was allowed. 7. Aggrieved by the said order, revenue preferred

Commissioner of Income Tax-II vs. M/s.Jayalakshmi Chits

ITTA/211/2008HC Telangana23 Mar 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

12 of the assessment order  it has been mentioned by Assessing Officer  that according to the assessment order for  Asst.   Year   1991­92   read   with   order   under  section 154 there is no carry forward loss,  therefore, no set off of the same is given.” 9.4. Referring to the above facts which are not in  dispute, it was submitted that the Tribunal

The Commissioner of Income Tax-II, vs. M/S Gulf Oil Corporation Pvt. Ltd.,

ITTA/195/2008HC Telangana23 Mar 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

12 of the assessment order  it has been mentioned by Assessing Officer  that according to the assessment order for  Asst.   Year   1991­92   read   with   order   under  section 154 there is no carry forward loss,  therefore, no set off of the same is given.” 9.4. Referring to the above facts which are not in  dispute, it was submitted that the Tribunal

The Commissioner of Income Tax - VI vs. M/s. Manikanta Iron AND Hardware

ITTA/196/2008HC Telangana02 Mar 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

12 of the assessment order  it has been mentioned by Assessing Officer  that according to the assessment order for  Asst.   Year   1991­92   read   with   order   under  section 154 there is no carry forward loss,  therefore, no set off of the same is given.” 9.4. Referring to the above facts which are not in  dispute, it was submitted that the Tribunal

Commissioner of Income tax-VI vs. M/s. Narpat Girji Constructions,

The appeal is allowed

ITTA/19/2015HC Telangana25 Mar 2015
Section 449Section 456Section 456(1)Section 456(2)Section 483

12 - OSA No. 19 of 2015 in portion of Sy,No.22,23 and 27 is concerned as per Schedule mentioned in Annexure A including lands of Sy.No.21, 22, 23 and 27 of Harihar Village and Taluk and further permit this Applicant to bid and buy these lands, in the interest of justice." 17. The learned Company Court vide ordered

The Commissioner of Income Tax vs. M/s.Sri Lakshmi Narasimha Construction

ITTA/211/2006HC Telangana21 Mar 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Section 247Section 98

12. Learned counsel for the petitioners has vehemently submitted that the best evidence is withheld and in order to substantiate the contention raised by the respondents, respondent no. 4, who happened to the landlord, would have been the best witness. However, it is a matter of record that the respondents-purchasers have mainly contested the suit though respondent no.4

The Commisioner of Income TAx-1 vs. Divya Shakti Granites Ltd.,

ITTA/178/2015HC Telangana04 Apr 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Section 96

Section 52 broadly enacts the English doctrine of lis pendens which does not depend upon notice/knowledge of litigation or consideration for the transfer. This view is reiterated by 12 (1857) 1 De G&J 566 - 52 - RFA No.178 OF 2015 C/W RFA CROB NO.19 OF 2015 the Apex Court decision in SHINGARA SINGH vs. DALJIT SINGH13. For the first time

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

12. It is also stated that, 2nd defendant gave various press statements to defeat the plaintiff’s claim. In one such statement, 2nd defendant state that a Trust is being formed and all the properties of 1st defendant and her husband including the plaint schedule property has to be transferred to the Trust. It is contended that 1st defendant being

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

12 (4-16), 13/1 (0-11) and 27(0-4). CS(OS) No. 78/2007 Page 2 of 43 2. The case of the plaintiff is that the four defendants had equal 1/4th co-ownership rights in the suit land and which suit land was agreed to be sold for a total price of Rs.5,32,91,250/-. The total price

Khorshed Shapoor Chenai vs. Asst.Commissioner of Income Tax,

Appeal stands disposed of setting aside the impugned

ITTA/47/2009HC Telangana27 Mar 2025

Bench: P.SAM KOSHY,NARSING RAO NANDIKONDA

12. The appellant received various amounts in installments from the respondent commencing from April 08, 1986 till August 31, 1988 and in all received `28,86,750/-. 13. Vide Ex.PW-2/10 dated August 31, 1988, Ex.PW-4 dated October 29, 1988 and Ex.P-5 dated May 13, 1989, the appellant wrote to the respondent stating that the money received

Commissioner of Income Tax, vs. M/s Y.Ramakrishna and others

ITTA/172/2003HC Telangana21 Jun 2011

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

Section 1Section 151Section 96

12 and the sale consideration is Rs. 13,31,750/- As per clause (2) the purchaser paid Rs. 2,00,000/- to the vendors towards advance, which the vendors received and acknowledged. As per clause (3) the balance of Rs. 1 1,31,750/- shall be paid by the purchaser to the vendors in 3 Bi-monthty instalments

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

12,773/- under the normal provisions and Rs.26,34,646/- under Section 115 JB of the Act. 3. The respondent assessee had two units: One unit was located in a ITA No.365/2018 Page 2 of 9 non-STPI zone and hence its income was taxable. The other unit was located in a STPI zone in Gurgaon and its income

THE PR COMMISSIONER OF INCOME TAX vs. M/s. Value Labs

ITTA/624/2018HC Telangana27 Dec 2018

Bench: P.KESHAVA RAO,V RAMASUBRAMANIAN

Section 10ASection 10A(4)

12 291 (Delhi) without appreciating the relevant facts and ignoring that this comparable was selected by the Assessee itself in its transfer pricing report. iv) Whether on the facts and circumstances of the case, the Tribunal was justified in rejecting Persistent Systems Private Limited, which was selected by Assessee in its transfer pricing report as a suitable comparable