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64 results for “transfer pricing”+ Section 28clear

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Key Topics

Section 26021Addition to Income20Section 260A16Section 10(20)10Section 809Section 8O8Section 10A7Section 47Section 966

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 Officer (TPO) or Dispute Resolution Panel (DRP) which comprises of three Commissioners and the Revenue or the assessee may feel dissatisfied, because of the reversal or modification of such findings by the Tribunal resulting in leaving out of certain comparables or adding on of certain comparables for determining the ‘Arm’s Length Price’ in the hands

THE COMMISSIONER OF INCOME TAX, HYDERABAD vs. M/S. ANDHRA PRADESH PAPER MILLS, HYDERABAD

ITTA/318/2005HC Telangana29 Nov 2017

Bench: The Trial Court. 4. The Brief Averments Of The Plaint, In O.S. No.25 Of 2002, Are As Under:

For Appellant: SRI. P RAJASEKHAR
Section 96

Showing 1–20 of 64 · Page 1 of 4

Deduction6
Exemption5
Double Taxation/DTAA4

price. For determining his willingness to perform his part of the contract, the conduct has to be properly scrutinised. There is no documentary proof that the plaintiff had ever funds to pay the balance of consideration. Assuming that he had the funds, he has to prove his willingness to perform his part of the contract. According to the terms

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

price which in fact was not received. Reference can be also made to Commissioner of Income Tax, Bombay versus M/s Godavari Corporation Limited, [1993] 200 ITR 567 (SC) and judgments of this Court in CIT versus Dinesh Jain, HUF, [2013] 352 ITR 629 (Del) and Commissioner of Income Tax versus Late Sh. Gulshan Kumar (Decd.) through

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

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

price; and (ii) In any other case [not being a case falling under sub-clauses (i) to (iv) of sub-section (1) of section 49], shall be taken to be nil” ITA 549/2011 Page 11 of 16 9. This provision clearly provides determining the cost of any relation to a capital asset being the right to manufacture, produce or process

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

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

price  lower than the market rate. If that be so,  the   question   of   inflating   the   loss   by  transferring   the   shares   to   group   company  would   not   arise.   Under   ordinary  circumstances,   it   is   always   open   to   the  assessee in his own wisdom to either hold on  to certain bunch of shares or to sell the  same to avoid further loss

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

ITTA/211/2008HC Telangana23 Mar 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

price  lower than the market rate. If that be so,  the   question   of   inflating   the   loss   by  transferring   the   shares   to   group   company  would   not   arise.   Under   ordinary  circumstances,   it   is   always   open   to   the  assessee in his own wisdom to either hold on  to certain bunch of shares or to sell the  same to avoid further loss

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

price  lower than the market rate. If that be so,  the   question   of   inflating   the   loss   by  transferring   the   shares   to   group   company  would   not   arise.   Under   ordinary  circumstances,   it   is   always   open   to   the  assessee in his own wisdom to either hold on  to certain bunch of shares or to sell the  same to avoid further loss

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

Section 457 of the Companies Act r/w Rule 9 of the Companies (Court) Rules. In Paragraph 11 of the said application, KIAMS submitted that the it would be constrained to get the property transferred into their name immediately, failing which, the Institution would not be recognized. It was also said that they were willing

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

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 paid or promised or part-paid and part-promised. Sale how made.— 3Such transfer, in the case of tangible immoveable property of the value of one hundred rupees and upwards, or in the case

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

price, and since all of these aspects are found in the two documents dated 25.9.2006 Ex.P-1 and Ex.P-2, hence I hold that these documents are complete contracts under the Indian Contract Act. CS(OS) No. 78/2007 Page 11 of 43 12(i) The argument urged on behalf of the learned counsel for the defendants that these documents cannot be said

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

price component is already paid and what remains to be paid is Rs.49,80,000/-. Vouchsafing the title to property is a predominant obligation of the vendor, vide condition Nos.6, 7 & 8 in Ex.P4, is not disputed before us. Paragraph 2 stipulates that the plaintiff has to pay this amount in two installments: First installment of Rs.34

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

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. Smt. Raj Kumari

Accordingly are partly allowed

ITTA/23/2008HC Telangana28 Mar 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

28 LPA-22-2008+ of the Constitution of India before Single Judge was also dismissed. Division Bench thereafter had entertained the letters patent appeal and held employer had been engaged in unfair labour practice and had directed to pay backwages and other benefits from the date of order of retrenchment till the date of retirement. It was also considered

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

28-02-2017 ANNEXURE - D CONFIRMING THE ORDER PASSED BY THE ASST. COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(2), BENGALURU & ETC. THIS I.T.A. COMING ON FOR ADMISSION, THIS DAY Dr. VINEET KOTHARI J. DELIVERED THE FOLLOWING:- JUDGMENT Mr.Aravind K.V. Adv. for Appellants-Revenue Ms.Manasa Ananthan, Adv. for Respondent-Assessee The Appellants-Revenue have filed this appeal u/s.260A

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

transferred outside India and the payments were also received outside India. It was pointed out that several activities relating to marketing and sales took place in India. Expatriates from GEII along with employees of GEIIPL constituting the Indian team were mostly involved and participated in the negotiation of prices. These price negotiations took place in India. The Indian customers discussed

COMMISSIONER OF INCOME TAX-II vs. M/S IJM (INDIA) INFRASTRUCTURE LIMITED

Appeal is dismissed as withdrawn

ITTA/595/2014HC Telangana19 Jul 2021

Bench: T.VINOD KUMAR,M.S.RAMACHANDRA RAO

For Appellant: SMT K. MAMATA CHOUDARY, SC for l.T. Dept
Section 260

Section 260 A of the lncome Tax Act 1961, against the order of the lncome Tax Appellate Tribunal, Hyderabad Bench 'A', Hyderabad in lTA.No.43/11yd12014 for assessment Year 200S -2010 dated 29-04-2014 preferred against the Order of the Additional Commissioner of lncome Tax ( Transfer Pricing ) Hyderabad, PAN No.AAAC170674 dated 28

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

28 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. admeasuring 1319 sq. mts. were shown. 4. By an order dated 14.11.1984 passed under section 8(4) of the Act, the Competent Authority found that except for the property shown at serial No.2, all the lands were H.U.F. properties

The Commissioner Of Income Tax (Central) vs. Madhu Enterprises

ITTA/455/2017HC Telangana06 Jul 2017

Bench: SANJAY KUMAR,GUDISEVA SHYAM PRASAD

price of goods taxable under Section 10 of the Act; ii) Transaction falling under Section 5(2), Section 6-A and Section 6(2) of the CST Act, 1956, iii) Value of transfer of a business as a whole iv) [ xxx] (iii) This sub-rule is not applicable, if the VAT dealer is making exempt transactions. 22. By comparing