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46 results for “transfer pricing”+ Section 35(1)(ii)clear

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Key Topics

Addition to Income14Section 260A13Section 26011Section 10(20)10Section 46Section 1516Section 12A6Section 965Section 143(3)5

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)

35 / 79 CRA-322-08gr distance of the line of WC and toilet”. He denied that to the rear side of the suit premises, previously, there was an otla and it was removed and put on it a rolling shutter, enclosed by defendants no.1 and 2. 46. As far as trial Court is concerned, the learned trial Judge

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

ITTA/455/2017HC Telangana06 Jul 2017

Bench: SANJAY KUMAR,GUDISEVA SHYAM PRASAD

Showing 1–20 of 46 · Page 1 of 3

Survey u/s 133A4
Exemption3
Double Taxation/DTAA3

ii)and 18(4)(iii) of the JVAT Act, without insertion of substituted proviso would reveal that 47 although in the aforesaid un-amended provisions also, provisions were incorporated for availing ITC in respect of “sales” falling under section 8(1) of the CST Act, 1956, but there was no provision which provided for forfeiture of the balance Input

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

ITTA/134/2016HC Telangana14 Jul 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

ii)and 18(4)(iii) of the JVAT Act, without insertion of substituted proviso would reveal that 47 although in the aforesaid un-amended provisions also, provisions were incorporated for availing ITC in respect of “sales” falling under section 8(1) of the CST Act, 1956, but there was no provision which provided for forfeiture of the balance Input

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

35. The most important provision concerning us in this batch of cases is Section 92-C of the Act which provides for ‘Computation of Arm’s Length Price’ and 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., 52/80 the said provision stipulates that

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

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)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

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 144CSection 260ASection 9(1)(vi)

price paid by the customer to the assessee and states that this is disproportionately high in comparison to the cost incurred by the assessee for the transponder. This according to the AO lead to an inference that the customers are compensating the assessee for not only the transponder cost but also the cost of the satellite. The AO did this

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

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

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

transferred to other Nortel Group Companies including the Assessee. 16. The AO was of the view that the Assessee had been incorporated solely with the sole motive to evade the taxes arising out of supply contract in India and in substance, the contracts were performed by Nortel Canada along with its LO and Nortel India, who acted in unison

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 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 an appeal to the Income-tax Appellate Tribunal. The Tribunal held that it is an undisputed fact that the assessee had developed

Commissioner of Income-Tax, vs. Rangaraya Medical College Old Students Association

ITTA/269/2005HC Telangana14 Mar 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

For Appellant: SRI CHALLA GUNARANJAN
Section 1Section 151

35 2. Andhra Pradesh Gas Power Corpn. Ltd., # 2O1,2nd Floor' My Home Sarovar Plaza, Secretariat Road, Hyderabad-500 063. ...RESPONDENT/RESPONDENT !.A. NO: 2 OF 200S{WAMP. NO: 1732 OF 2005) Petition under section 151 cPC praying that in the circumstanc€s stated in the aflldavit filed in support of the petition, the High Court may be pleased to suspend

The Commissioner of Income Tax-II, vs. M/s Padmapriya Real Estates AND Financiers

In the result, the appeal is allowed and the impugned judgment passed by

ITTA/478/2006HC Telangana10 Mar 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Section 13(1)(e)Section 13(2)Section 313

35. PW-24 J.R. Jimwale is the Assistant Administrative Officer LIC, Dhamtari has also proved the insurance policies of appellant as well as his wife and the document Ex.P/67, Ex.P/68 and Ex.P/69. 36. PW-25 Radheshyam Pawar is the Assistant (Legal Cell), Municipal Council, Dhamtari proved the sanction letter of map for construction of the house which is Ex.P/73

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

35,000 19.2.92 187.00 21.1.92 142.00 Rs.7,50,000/­ Total LossRs.16,88,250/­ 8.2. The   Assessing   Officer   after   verification  found that the assessee had sold the shares  prior in point of time without involving any  broker, and thereafter, purchased the shares  through   brokers.   The   Assessing   Officer  noticed that shares of Mysore Cement were not  sold   at   the   prevailing   market   price

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

ITTA/211/2008HC Telangana23 Mar 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

35,000 19.2.92 187.00 21.1.92 142.00 Rs.7,50,000/­ Total LossRs.16,88,250/­ 8.2. The   Assessing   Officer   after   verification  found that the assessee had sold the shares  prior in point of time without involving any  broker, and thereafter, purchased the shares  through   brokers.   The   Assessing   Officer  noticed that shares of Mysore Cement were not  sold   at   the   prevailing   market   price

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

35,000 19.2.92 187.00 21.1.92 142.00 Rs.7,50,000/­ Total LossRs.16,88,250/­ 8.2. The   Assessing   Officer   after   verification  found that the assessee had sold the shares  prior in point of time without involving any  broker, and thereafter, purchased the shares  through   brokers.   The   Assessing   Officer  noticed that shares of Mysore Cement were not  sold   at   the   prevailing   market   price

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

The Commissioner of Income Tax IV vs. New Bombay Goods Transport

ITTA/249/2013HC Telangana11 Jul 2013
Section 4

1) that the deeming provision in Section 4(2) was subject to the provisions contained in Section 3 of the CST Act. If the sale of goods fell within the ambit of Section 3(a) of the CST Act, it would then be an inter-state sale, notwithstanding that, in terms of Section 4(2)(a), the ascertained goods were

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 100 CPC is directed against the common judgment and decree dated 7-10-2006 passed in R.A.Nos.33 and 35 of 2002 by the District and Sessions Judge and Presiding Officer, Fast Track Court –II, Bangalore Rural District, Bangalore, wherein appeal filed by the plaintiff -K.T. Plantations Private Limited in RA 3 No.33/2002 came to be allowed

The Commissioner of Income Tax (IT and TP) vs. M/s. Idea Cellular Limited

Accordingly, the learned appellate authority has rightly dismissed the

ITTA/14/2021HC Telangana19 Oct 2023

Bench: P.SAM KOSHY,LAXMI NARAYANA ALISHETTY

Section 107

price. 27. In that view of the matter, as it is admitted case of the petitioner that the electricity generated in 540 MW Power Plant is used in the course of or furtherance of his business, which is evident from Form G provided by the taxpayer i.e. the petitioner herein, the petitioner would not be entitled for ITC to electrical

Suchirindia Infratech Pvt. Ltd vs. Dy. Commissioner of Income-Tax

Accordingly, the learned appellate authority has rightly dismissed the

ITTA/15/2021HC Telangana30 Apr 2021

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

Section 107

price. 27. In that view of the matter, as it is admitted case of the petitioner that the electricity generated in 540 MW Power Plant is used in the course of or furtherance of his business, which is evident from Form G provided by the taxpayer i.e. the petitioner herein, the petitioner would not be entitled for ITC to electrical