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35 results for “transfer pricing”+ Section 36(1)(iv)clear

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Key Topics

Section 8019Section 260A9Addition to Income9Section 1516Section 965Section 2605Section 143(3)5Section 9(1)(vi)5Section 44

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)

36 / 79 CRA-322-08gr the defendants did not examine previous landlord who could have stated about alleged construction in the suit premises of defendant no.2. The learned trial Judge, therefore, held that the plaintiffs have proved that the defendants have carried out additions and alterations of permanent nature unauthrosiedly and illegally. 47. In paragraph 39, the learned trial

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

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

ITTA/473/2012

Showing 1–20 of 35 · Page 1 of 2

Survey u/s 133A2
Double Taxation/DTAA2
HC Telangana
09 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

IV) is in affirmative, whether in absence of machinery provision for giving effect to the amendments made in section 18(4)(ii) and 18(4)(iii) of the JVAT Act, upto 16.2.2017, the said provisions are unworkable and cannot be acted upon. Questions No. I and II 25. We have already in the preceding paragraphs of the judgment quoted

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

ITTA/134/2016HC Telangana14 Jul 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

IV) is in affirmative, whether in absence of machinery provision for giving effect to the amendments made in section 18(4)(ii) and 18(4)(iii) of the JVAT Act, upto 16.2.2017, the said provisions are unworkable and cannot be acted upon. Questions No. I and II 25. We have already in the preceding paragraphs of the judgment quoted

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

iv) Letter dated 4.6.2010 issued by the appropriate authority notifying the Zonal Development Plan as Ex.PW5/2. (v) Certified copies of sale deeds showing purchase of various lands by the plaintiff in around the vicinity of the suit land/village Goela Khurd as Ex.PW-1/16 to Ex.PW1/21 for showing payments made by the plaintiff for purchase of these lands

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

36 l.A. NO: 1 OF 2005(WAMP. NO: 2371 OF 2005) Petition under Section 1 51 cpc praying that in the circumstances stated in the affidavit filed in support of the petition, the High Court may be pleased to suspend the judgment under appeal pending the disposal of the above W.A. Counsel for the Appellants: SRI VENKAT CHALLA

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

36 thereto of which the assessee is the owner, other than such portions of such property as he may occupy for the purposes of any business or profession carried on by him the profits of which are chargeable to income-tax, shall be chargeable to income-tax under the had ‘Income from house property’.” The section itself indicates that merely

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

ITTA/249/2013HC Telangana11 Jul 2013
Section 4

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

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

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

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

36. W.P.(C) No.17240/2020 is filed by a partnership firm “Poomala Granites”, challenging Exhibit-P21 order of the Tahsildar, Thrissur, denying permission to conduct quarry in the assigned lands. Petitioner therein has contended that even though they have produced Exhibit-P11 mining sketch, WP(C). 11249/2010 & other contd cases. -:70:- it has not been countersigned by the Tahsildar, and therefore

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

36. As stated above, this court while admitting the appeal on 11-06-2013 framed the following substantial question of law: 1. Can there be a declaration that sale deed dated 16-2-1992 which is unregistered is valid and does 40 it not negate the Section 17 of the Registration Act? 2. Can there be a declaration that

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

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

36 + ITA 263/2022 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. 37 + ITA 220/2023 THE COMMISSIONER

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

36 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. Division Bench of this Court has clearly held that it is the nature and scope of holding that is decisive on this point if individuals, with specified shares, though acquired under or through a single source or transaction

THE COMMISSIONER OF INCOME TAX III, vs. M/S. SAVIJANA SEA FOODS PVT. LTD.,

Appeals of the Revenue are dismissed

ITTA/55/2010HC Telangana20 Dec 2024

Bench: J SREENIVAS RAO,ALOK ARADHE

Section 260

iv. depreciation of plant and equipment that cannot be allocated to a particular contract.” 21. The pros and cons of the CCM are discussed in para 10. Para 11.2 of AS 7 states that when a contractor uses a particular method of accounting for a contract, “then in respect of all other contracts that meet similar criteria, the same method

Commissioner of Income Tax, vs. M/s. Kokivenkateswara Reddy AND others,

Appeals of the Revenue are dismissed

ITTA/210/2003HC Telangana21 Jun 2011

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

Section 260

iv. depreciation of plant and equipment that cannot be allocated to a particular contract.” 21. The pros and cons of the CCM are discussed in para 10. Para 11.2 of AS 7 states that when a contractor uses a particular method of accounting for a contract, “then in respect of all other contracts that meet similar criteria, the same method