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17 results for “transfer pricing”+ Section 143(1)(a)clear

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Key Topics

Section 260A9Section 2608Section 143(3)6Section 80H6Section 9(1)(vi)5Addition to Income5Section 92C4Section 804Section 96

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

1) (d) of the Act. Section 254 of the Act empowers the Appellate Tribunal to pass such orders on the appeals ‘as it thinks fit’ after giving an opportunity of hearing to both the parties. 38. From the aforesaid Scheme of assessment with regard to international transactions, it is clear that the process of determination of ‘Arm’s Length Price

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 144C
4
Transfer Pricing3
Deduction3
Disallowance2
Section 260A
Section 9(1)(vi)

143(1) on 26.03.2009. In the previous year, the receipts accrued and arising in India to the assessee had been treated as “royalty”. Consequently, the assessee was asked to show cause why the receipts may not be treated as royalty and taxed accordingly as had been done in the past. By its letters dated 03.09.2009 and 16.11.2009, the assessee submitted

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

1)(2), BANGALORE. ... APPELLANTS (BY SRI. JEEVAN J. NEERALGI, ADV.,) AND: M/S. PAGE INDUSTRIES LTD ABBAIAH REDDY INDUSTRIAL AREA JOCKEY CAMPUS, NO.6/2 & 6/4 HONGASANDRA, BEGUR HOBLI BANGALORE-560068 PAN: AABCP2K630D. ... RESPONDENT (BY SRI. CHYTHANYA K.K. ADV.) - - - THIS I.T.A. IS FILED UNDER SEC. 260-A OF INCOME TAX ACT 1961, ARISING OUT OF ORDER DATED 24.06.2016 PASSED

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

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

1. Nortel Networks India International Inc. (hereafter ‗the Assessee‘) has preferred the present appeals under Section 260A of the Income Tax Act, 1961 (hereafter ‗the Act‘) against orders passed by the Income Tax Appellate Tribunal (hereafter ‗ITAT‘). ITA Nos. 669/2014, 671/2014 and 672/2014 are appeals preferred by the Assessee against a common ITA 666/2014 & Ors. Page 4 of 57 order

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

1) Whether the Appellate Authorities were correct in holding that telecommunication expenses and traveling expenses incurred in foreign currency reduced from export turnover has to be reduced from total turnover for computing 3 deduction under Section 10A of the Act in the absence of any provisions in Section 10A of the Act which requires the concerned expenses to be reduced

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

1) of the Act on 28.08.2006. The case was selected for scrutiny by issue of notice under Section 143(2) dated 25.07.2006, which was duly served on the assessee Company. The - - 8 assessee in response to the notice issued appeared on 13.12.2007 and 14.12.2007 and filed written submissions. The assessee claimed that they are in the business of providing comprehensive

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

Section 143(2) was issued on 19.09.2008 upon the assessee. Since there were 3 international transactions carried out by the QGSL, a reference was made to Transfer 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

Commissioner of Income Tax-1 vs. Agricultural Market Committee

ITTA/186/2011HC Telangana21 Apr 2011

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

Section 151Section 96

transfer is, therefore, not vitiated by lis pendence. Section 52 of the Act does not wipe out the transaction altogether. 5.PrinciplegroundsofcontentioninC.C.C.A.No.186 of 2O11 are as under:- TheLowerCourtfailedtoseethatRespondentsl to 11 and 14 (Vendors) failed to comply with the condition of obtaining NOC under IT Act, which was mandatory on the date of the agreement of sale Ex. A3 and filing

Commissioner of Income Tax vs. Agrilcultural Market Committee

ITTA/148/2011HC Telangana20 Apr 2011

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

Section 151Section 96

transfer is, therefore, not vitiated by lis pendence. Section 52 of the Act does not wipe out the transaction altogether. 5.PrinciplegroundsofcontentioninC.C.C.A.No.186 of 2O11 are as under:- TheLowerCourtfailedtoseethatRespondentsl to 11 and 14 (Vendors) failed to comply with the condition of obtaining NOC under IT Act, which was mandatory on the date of the agreement of sale Ex. A3 and filing

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

143(3) after making various additions and disallowances. Being aggrieved by the additions and disallowances made by the Assessing Officer, the apepllant preferred first appeal before the learned CIT(Appeals) who granted partial relief to the appellant. 2.1 Being aggrieved by the order passed by the learned Page 2 of 14 O/TAXAP/186/2003 JUDGMENT CIT(A) the appellant as well

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)

143(3) of the Act on 28.3.2002 determining the total income of Rs.2,26,94,970/- by including a sum of Rs.2,00,00,000/- received by the appellant from M/s. Sun Pharmaceuticals Industries Limited (hereinafter referred to as “SPIL”) under the head “income from other sources” treating the same as revenue receipt and subjecting the same

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

price, and requesting them to place an order with the foreign headquarters were not auxiliary or preparatory in nature. The observations and findings of the High Court are eerily similar to the facts of this case: “Relying on these provisions, it is contended by the assessee that the liaison office was opened to act as a communication channel between

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

ITTA/325/2005HC Telangana07 Apr 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Section 143(3) of the Act and the income of the appellant was determined at Rs.84,95,035/-. The assessing Officer (hereinafter „AO‟) came to the conclusion that since the payment of Rs.1 Crore was absent in the earlier license agreement and it was for use of the brand, the expenditure of Rs.1 Crore cannot be related to the business

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

1 and 2 companies and certain other individuals as Directors of 4 listed companies, 3 subsidiaries of one listed company and an unlisted company is bad in law since the Joint APLs merely represents the estate of PDB and thus, had no rights to seek appointment of Directors in companies in which PDB was not a "Member". Further, without prejudice

The Pr. Commissioner of Income tax (Central), vs. Sri Vaishnavi Educational Society,

ITTA/622/2015HC Telangana01 Jun 2016

Bench: The Hon’Ble Mr. Justice Aravind Kumar W.P. No.51929/2014 C/W W.P.Nos.42063/2012, 30494/2013, 42671/2013, 638/2014, 797/2014, 1089/2014, 3211/2014, 3389/2014, 6180/2014, 10356/2014, 12014/2014, 12015/2014, 13043/2014, 13045/2014, 13206/2014, 13207/2014, 13398/2014, 13774/2014, 14149/2014, 14161/2014, 14494/2014, 14502/2014, 14521/2014, 14689/2014, 16646/2014, 17051/2014, 17594/2014, 19729/2014, 21158/2014, 23897/2014, 28861/2014, 30731/2014, 31723/2014, 33774/2014, 33777/2014, 34084/2014, 34259/2014, 34272/2014, 34391/2014, 35204/2014, 35243/2014, 35247/2014, 35305/2014, 35609/2014, 36164/2014, 36166/2014, 36489/2014, 36525/2014, 36971/2014, 37446/2014, 38055/2014, 38463/2014, 38471/2014, 38472/2014, 38661/2014, 38753/2014, 39383/2014, 39633/2014, 39832/2014, 40204/2014, 40379/2014, 41394/2014, 41422/2014, 41427/2014, 41428/2014, 41858/2014, 43815/2014, 43963/2014, 44306/2014, 44527/2014, 44742/2014, 44835/2014, 45486/2014, 46766/2014, 47103/2014, 47105/2014, 47106/2014, 47107/2014, 47608/2014, 47731/2014, 47821/2014, 47860/2014, 47913/2014, 48577/2014, 48880/2014, 49567/2014, 50260/2014, 50533/2014, 51294/2014, 51930/2014, 51931/2014, 51932/2014, 52760/2014, 53854/2014, 54059/2014, 54083/2014, 54236/2014

1. STATE OF KARNTAKA REP BY ITS SECRETARY URBAN DEVELOPMENT DEPARTMENT M S BUILDING, DR AMBEDKAR VEEDHI BANGALORE-560001 2. BANGALORE DEVELOPMENT AUTHORITY REP BY ITS COMMISSIONER KUMARA PARK WEST BANGALORE-560020 3. SPECIAL LAND ACQUISITION OFFICER BANGALORE DEVELOPMENT AUTHORITY KUMARA PARK WEST BANGALORE-560020 …RESPONDENTS (BY SRI. G.V. SHASHIKUMAR, AGA FOR R1; SRI. M.N. RAMANJANEYA GOWDA, ADVOCATE

The commissioner of Income Tax IV vs. M/s Lanco Kondapalli Power (P) Ltd

ITTA/121/2013HC Telangana26 Jul 2013

1-2-oswp-1494-2023-J+.docx a company incorporated under the Companies Act, 1956 having its corporate office at "BKT House", C/15, Trade World, Kamala Mills Compound, Senapati Bapat Marg, Lower Parel, Mumbai 400 013. …Petitioner ~ versus ~ 1. The State of Maharashtra, through the Department of Registration and Stamps, Ministry of Revenue, Government of Maharashtra, Mantralaya, Mumbai