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39 results for “transfer pricing”+ Section 35(1)(iv)clear

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Key Topics

Section 260A11Section 10(20)10Addition to Income10Section 2606Section 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

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

ITTA/318/2008HC Telangana01 Mar 2011

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

Showing 1–20 of 39 · Page 1 of 2

Exemption3
Survey u/s 133A2
Double Taxation/DTAA2
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, 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

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)

iv), (iva) and (v). 9. In ITA 500/2012 the assessee, Shin had on 30.10.2007 filed a NIL return of income, which was processed under Section 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

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

ITTA/455/2017HC Telangana06 Jul 2017

Bench: SANJAY KUMAR,GUDISEVA SHYAM PRASAD

35, 37, 38, 39 and 41. (4) Jayam and Company Vs Assistant Commissioner and Anr, reported in (2016) 15 SCC 125 (relevant paragraphs 2, 6, 16 to 19); (5) Union of India & Ors Vs N.S. Rathnam & Sons, reported in (2015) 10 SCC 681, relevant paragraph 1, 12, 13 to 21. 14. Mr. Ajit Kumar, learned Advocate General and Mr. Atanu

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

ITTA/134/2016HC Telangana14 Jul 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

35, 37, 38, 39 and 41. (4) Jayam and Company Vs Assistant Commissioner and Anr, reported in (2016) 15 SCC 125 (relevant paragraphs 2, 6, 16 to 19); (5) Union of India & Ors Vs N.S. Rathnam & Sons, reported in (2015) 10 SCC 681, relevant paragraph 1, 12, 13 to 21. 14. Mr. Ajit Kumar, learned Advocate General and Mr. Atanu

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

iv). Whether, without prejudice, the Tribunal erred in attributing 50% of the alleged profits to the alleged PE of the Appellant in India and whether such approach and quantification was inconsistent with Article 7 of the DTAA? ITA 666/2014 & Ors. Page 7 of 57 (v). Whether Tribunal erred in confirming the levy of interest under section 234B

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-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

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

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

iv) the price or consideration. The word 'price' is used in its ordinary sense as meaning money only. It is used in the same sense as in Section 77 of the Indian Contract Act, 1872 (in short, the 'Contract Act'). As has been observed by the Supreme Court in Commissioner of Income-tax V. Motor and General Stores

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

ITTA/249/2013HC Telangana11 Jul 2013
Section 4

35. AIR 1975 SC 887 36. AIR 1971 SC 477 37. (1983) 54 STC 45 (Guj) 38. AIR 1981 SC 446 39. (1973) 2 SCC 551 40. AIR1952SC366 41. AIR 1964 SC 1752 42. AIR 1953 SC 333 43. AIR 1968 Pat. 329 44. (1993) 90 STC 1

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

price paid or promised or part- paid and part-promised. Sale how made.—Such transfer, in the case of tangible immoveable property of the value of one hundred rupees and upwards, or in the case of a reversion or other intangible thing, can be made only by a registered instrument. 1In the case of tangible immoveable property of a value

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

iv. The Company Court after hearing the parties in Company Application No.826/2011 has dismissed the application vide impugned judgment and order dated 21.07.2015, on the ground that the Company Application was barred by Limitation. BACKGROUND OF THE CASE: 4. The Mysore Kirloskar Limited was ordered to be wound up by the Company Court vide order dated 01.04.2004 in Company Petition

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

The Commissioner of Income Tax vs. M/s Natco Exports Ltd.

In the result, the judgment and decree passed by the

ITTA/218/2003HC Telangana11 Jul 2017

price of the land as per the circle rate fixed by the Government and would not mention the entire consideration money of Rs. 3,35,000/- because it would cost them higher stamp fee and court fee and they may be involved in income tax. They further stated that at the request of the plaintiffs they executed the sale deeds

The Pr. Commissioner of Income Tax-2 vs. M/s. GJ Trading Pvt Ltd

ITTA/246/2022HC Telangana05 Sept 2022

Bench: C.V. BHASKAR REDDY,UJJAL BHUYAN

35 + ITA 249/2022 THE COMMISSIONER OF INCOME TAX (INTERNATIONAL TAX)-1 NEW DELHI .....Appellant Through: Mr. Puneet Rai, SSC with Mr. Ashvini Kr., Mr. Rishabh Nangia, JSCs, Mr. Nikhil Jain and Ms. Srishti Sharma, Advs. versus M/S EXPEDITORS INTERNATIONAL OF WASHINGTON INC .....Respondent Through: Mr. Deepak Chopra, Mr. Rohan Khare and Mr. Priyam Bhatnagar, Advs. 36 + ITA 263/2022 THE COMMISSIONER