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55 results for “transfer pricing”+ Section 34clear

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Key Topics

Addition to Income17Section 260A15Section 26012Section 10(20)10Section 809Section 8O8Section 967Section 47Section 1516

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 Date of Judgment 25-06-2018 I.T.A.No.536/2015 C/w I.T.A.No.537/2015 Pr. Commissioner of Income Tax & Anr. Vs. M/s. Softbrands India P. Ltd., 51/80 Pricing cases of International Taxation under these provisions in income arising from international transactions which shall be computed having regard to the ‘Arm’s Length Price’ (Sec.92). 33. Section 92-A defines an ‘Associate Enterprise

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

Showing 1–20 of 55 · Page 1 of 3

Survey u/s 133A4
Deduction3
Exemption3

34, the following section insert:— “34A. Person claiming under document for sale of property also to sign document.—Subject to the provisions of this Act, no document for sale of peoperty shall be registered under this Act, unless the person claiming under the document has also signed such document.”. [Vide Tamil Nadu Act 28 of 2000]. 35. Procedure on admission

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-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

price of the said land and buy the scheduled property situated in 6.3 acres, immediately. 19. Prayer was sought for a direction to the Official Liquidator to sell the said 6.3 acres of schedule property wherein the Institution of the KIAMS is situated by accepting the amount stated therein. 20. Company Court vide order dated 30.09.2008 took note

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 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

price to M/s. Mac Charles Pvt. Ltd. The said explanation was not accepted by the Assessing Authority which adopted the market value of the property at Rs.1193/- per sq. ft. and arrived at Short Term Capital Gain at Rs.6,34,26,274/- and levied Capital Tax on the said amount. 6. Aggrieved by this order, the assessee preferred an appeal

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

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

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

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 was exempted under Section

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

Section 34 of the Act which will be discussed in some other appropriate case on merits. Page 38 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. Since on merits, we have found in the present case that the proceedings under the ULC Act, 1976 were concluded properly

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

ITTA/455/2017HC Telangana06 Jul 2017

Bench: SANJAY KUMAR,GUDISEVA SHYAM PRASAD

34 manufacturing process and are not transferred into or existent in the finished product whether as goods or in any other form’ The said amendment was also initially given retrospective effect with effect from 01.04.2015. (iii) Amendment No. 3 Vide notification dated 08.02.2016, Proviso inserted in Clause-(ii) and (iii) of sub-section(4) of Section-18 which was inserted

S.l. Shiva Raj vs. Commissioner of Income Tax,

ITTA/134/2016HC Telangana14 Jul 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

34 manufacturing process and are not transferred into or existent in the finished product whether as goods or in any other form’ The said amendment was also initially given retrospective effect with effect from 01.04.2015. (iii) Amendment No. 3 Vide notification dated 08.02.2016, Proviso inserted in Clause-(ii) and (iii) of sub-section(4) of Section-18 which was inserted

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

Transfer Pricing Adjustments’ made by the concerned authorities below. We consider it appropriate to quote Date of Judgment 05-07-2018 I.T.A.No 700/2017. The Pr. Commissioner of Income-Tax, CIT (A) & Anr. Vs. M/s. Global E-Business Operations Pvt. Ltd., 7/15 from the order of Tribunal rejecting the Application seeking a review before Tribunal as hereunder:- “7.3 We have considered

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

transfer and, therefore, respondent no. 1 or his father had become full owner of the suit land. 37 LPA-22-2008+ 39. Aforesaid aspects show that the tahsildar had taken into account certain documents and considered the matter and rejected the application. It appears that neither the appellate nor the revisional authority has taken into account various facts and circumstances

The Commissioner of Income -Tax - III, vs. Shri Taher Ali

ITTA/322/2008HC Telangana04 Apr 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Section 108Section 13(1)(a)Section 13(1)(b)Section 13(1)(e)

34 / 79 CRA-322-08gr therein. He further deposed that “it is not true that my statement as regards to the rolling shutter and removal of partition wall is not correct.” 44. Plaintiffs examined PW 4 Prafull Powale, Structural Engineer. He had produced report dated 7.7.2003 at Exh.H. In paragraph 10 of the report, he mentioned about demolition

Principal Commissioner of Income Tax - 5 vs. M/s Vijay Textiles Limited

The appeal is dismissed

ITTA/541/2015HC Telangana16 Feb 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Section 167BSection 2(31)Section 2(47)Section 260Section 3Section 4Section 67A

price of Rs.150/- sq.ft for the land has been fixed, but land was the capital to be introduced by the 32 assessee for the purpose of endeavor. That assessee had considerable stake, is clear from the fact that asseessee was obliged to offer the land as security for raising loans. Assessee had parted with possession with clear knowledge that

Srinivasa Resorts Limited, vs. The Commissioner of Income Tax, AP. Hyderabad.

The appeal is partly allowed;

ITTA/273/2007HC Telangana28 Aug 2023

Bench: P.SAM KOSHY,LAXMI NARAYANA ALISHETTY

Section 96

price, the Plaintiffs filed a suit for injunction in OS.No.7269/1995. The Trial Court initially granted an order of Temporary Injunction restraining the Defendant from alienating the suit property. Thereafter, since the Defendant, inspite of service of summons, did not appear, he was placed ex parte. The Trial Court, vide its judgment and decree dated 30.7.1996, decreed the said suit