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

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

260A of the Act is barred. To that extent, the Senior Counsel is correct and is well supported by the ratio in S.P.Mansinghka (P) Ltd. The said case arose under Section 55 of the 1922 Act which is the precursor of Section 256(1) of the Act. Ruling on the scope of the said provision, the Division Bench

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

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

260A of the Act is barred. To that extent, the Senior Counsel is correct and is well supported by the ratio in S.P.Mansinghka (P) Ltd. The said case arose under Section 55 of the 1922 Act which is the precursor of Section 256(1) of the Act. Ruling on the scope of the said provision, the Division Bench

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

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

260A of the Act is barred. To that extent, the Senior Counsel is correct and is well supported by the ratio in S.P.Mansinghka (P) Ltd. The said case arose under Section 55 of the 1922 Act which is the precursor of Section 256(1) of the Act. Ruling on the scope of the said provision, the Division Bench

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

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

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

260A of the Act is barred. To that extent, the Senior Counsel is correct and is well supported by the ratio in S.P.Mansinghka (P) Ltd. The said case arose under Section 55 of the 1922 Act which is the precursor of Section 256(1) of the Act. Ruling on the scope of the said provision, the Division Bench

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

Bench: RAMESH RANGANATHAN,KONGARA VIJAYA LAKSHMI

Section 260A of the Act comprise the General Electric group of companies: GE Energy Parts Inc (“GEP” hereafter); General Electric International Operations Company Inc. (“GEIOC” hereafter); GE India Industrial Pvt. Ltd and (GEIIPL). All challenge a common order of the Income Tax Appellate Tribunal (“ITAT”) which concluded that the appellant PE in India and were, therefore, liable to file income

THE PRL. COMMISSIONER OF INCOME TAX-4, HYDERABAD vs. M/S PEGASYSTEMS WORLDWIDE INDIA PVT. LTD. HYDERABAD

Bench: P.SAM KOSHY,NARSING RAO NANDIKONDA

Transfer Pricing)-ll, 3'd iioor, O Block, I T. Towers, A C Guards, Hyderabad - 500004' Between: The Pr. Commissioner of lncome-Tax-4, Hyderabad- AND Counsel for the APPellant M/s Pegasystems Worldwide lndia P. LTD. DLF Cybercity, 3rd floor, Block No 2 Gachibowli, HYderabad-500 032 : Mr. J. V. Prasad Senior Standing Counsel forthe lncome Tax Depadment) Counsel

The Commissioner of Income Tax, vs. M/s. Laila Impex,

Accordingly answered against the Revenue. The appeals fail and are dismissed, without

260A of the Income Tax Act 1961 (“the Act”) are preferred against orders of the Income Tax Appellate Tribunal (“ITAT”), which upset Assessment Orders that ruled that the income derived by the assessees through data transmission services was taxable as royalty under Section 9(1)(vi) of the Act as well as Article 12 of the relevant Double Tax Avoidance

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

Bench: P.SAM KOSHY,NARSING RAO NANDIKONDA

260A of the Income Tax Act, 196 I (for short, the Act, 196 1') aggrieved by the order, dated 20.O7.2012 in ITA No. 1095 /Hyd/2OO9, dated 2O.O7.2O12, passed by the Income-Tax Appellate Tribunal, Bench 'B', Hyderabad, (for short, 'the Tribunal') for the Assessment Y ex 2006-2007 . 2. Brief facts of the case are that the assessee

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

The appeal is dismissed

Bench: P.SAM KOSHY,NARSING RAO NANDIKONDA

260A of the Income Tax Act, 1961 (for short, 'the Act, 1961) aggrieved by the order, dated 20.07.2012 tn ITA No.lO95/Hyd/2009, dated 2O.O7.20L2, passed by the lncome-Tax Appellate Tribunal, Bench B', Hyderabad, (for short, 'the Tribunal') for the Assessment Year 2006-2007 . 2. Brief facts of the case are that the assessee is a Iimited company engaged

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

The appeal is dismissed

Bench: P.SAM KOSHY,NARSING RAO NANDIKONDA

Section 260A of the Income Tax Act, 1961 is directed against the order dated 23.12.2011 passed by the Income Tax Appellate Tribunal in ITA 2320/Del/2010 in respect of the assessment year 2006-07. 2. Essentially, the revenue has proposed the following questions as substantial questions of law:- ITA 569/2012 Page 2 of 6 “(1) Whether on the facts and circumstances

Principal Commissioner of Income Tax-3 vs. M/s Sri Indra Power Energies Limited

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

260A of the Income Tax Act, 1961 (for short ‘Act’) raising purportedly certain substantial questions of law arising from the order of the Income Tax Appellate Tribunal, ‘C’ Bench, Bangalore (for short ‘Tribunal’) dated 30.04.2015 passed in I.T(TP)A No.1437/Bang/2014 for the A.Y.2009-10. 2. This appeal has been ADMITTED on 11.03.2016 to consider the substantial question of law Nos.2

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

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 dated 13th June, 2014 passed by the ITAT in ITA Nos. 1119, 1120 and 1121/Del/2010, which

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

Bench: CHALLA KODANDA RAM,G.CHANDRAIAH

260A of the Income Tax Act, 1961 (Act, for short) pertaining to Assessment Years 1989-90 and 1990-91. 2. By order dated 9th October, 2002, ITA No. 93/2002 was admitted for hearing on the following substantial question of law: “Whether the Tribunal was right in holding that the lump sum payment

Commissioner of Income Tax, Guntur. vs. Agricultural Market Committee, Kangiri.

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

260A of the Income Tax Act, 1961, (the IT Act, for brevity), by the Commissioner of Income Tax. These twelve appeals are against the common order passed by Income Tax Appellate Tribunal, Visakhapatnam Bench. Therefore, it is convenient to dispose them by a common Judgment. FACTUAL BACKGROUND The following brief fact of the matter is culled out from I.T.T.A.No

Commissioner of Income Tax, vs. Agricultural Market Committee,

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

260A of the Income Tax Act, 1961, (the IT Act, for brevity), by the Commissioner of Income Tax. These twelve appeals are against the common order passed by Income Tax Appellate Tribunal, Visakhapatnam Bench. Therefore, it is convenient to dispose them by a common Judgment. FACTUAL BACKGROUND The following brief fact of the matter is culled out from I.T.T.A.No

K.V.D.PRASAD RAO vs. THE JT.COMMISSIONER OF INCOME TAX

Bench: C.V. BHASKAR REDDY,UJJAL BHUYAN

price ancl the other component represented by non-competing fee ol' Rs.28/- per share; whatever be the anificial division, both th.' components represented sale corsideration for the transicr ol sh,rres. 'lhereiore, the finding of the revenue authoritir.s trcirtinq tlie sale consideration @ Rs.43/ - per share for ri'orking olrr rhc cr;rital gains on the sale of shares transferred

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

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

SECTION 260-A OF INCOME TAX ACT 1961, PRAYING TO DECIDE THE FOREGOING QUESTION OF LAW AND / OR SUCH OTHER QUESTIONS OF Date of Judgment -20-07-2018 I.T.A.No.542 /2015 Pr.Commissioner of Income Tax & Anr., Vs. M/s. SunGard Solutions (India) Pvt. Ltd., 2/13 LAW AS MAY BE FORMULATED BY THE HON’BLE COURT AS DEEMED FIT AND SET ASIDE

Sarwar Ahuja, vs. Income Tax Officer, Ward 6(1),

Accordingly dismissed. Pending applications are also dismissed

Bench: The Learned Itat Assailing The Order Dated 05.01.2024 Passed By The Assessing Officer [Ao] Under Section 147 Read With Section 144C(13) Of The Act. 3. The Assessee Is A Company, Which Is Tax Resident Of The United States Of America [Usa]. The Assessee Has Also Furnished A Tax Residency Certificate [Trc] From The Concerned Authorities Of The Said Country. Digitally Signed By:Tarun Rana Signing Date:01.06.2025 13:30:53 Signature Not Verified

260A of the Income Tax Act, 1961 [Act] impugning an order dated 22.08.2024 [impugned order] passed by the learned Income Tax Appellate Tribunal [ITAT] in ITA No.988/Del/2024 for Assessment Year [AY] 2018-19 captioned Goodrich Corporation v. ACIT. 2. The Assessee had preferred the aforementioned appeal before the learned ITAT assailing the order dated 05.01.2024 passed by the Assessing Officer