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26 results for “transfer pricing”+ Section 36(1)(vi)clear

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Key Topics

Section 260A9Section 9(1)(vi)5Addition to Income5Section 44Section 214Section 13(1)(a)3Section 1083Double Taxation/DTAA3Section 260

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 - III, vs. Shri Taher Ali

ITTA/322/2008HC Telangana04 Apr 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Showing 1–20 of 26 · Page 1 of 2

2
Section 2(31)2
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 (Central) vs. Madhu Enterprises

ITTA/455/2017HC Telangana06 Jul 2017

Bench: SANJAY KUMAR,GUDISEVA SHYAM PRASAD

VI, Industrial Area, Gamharia, Jamshedpur through its Director, Sudhir Rai ..... … Petitioner 25 Versus 1. The State of Jharkhand, through the Secretary, Finance Department, Project Building, Dhurwa, Ranchi 2. The Commissioner of Commercial Taxes, Project Bhawan, Dhurwa, Ranchi 3. Joint Commissioner of Commercial Taxes (Administration), Jamshedpur, Division, Jamshedpur. 4. Deputy Commissioner of Commercial Taxes, (Adityapur Circle), Jamshedpur 5. Assistant Commissioner

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

ITTA/134/2016HC Telangana14 Jul 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

VI, Industrial Area, Gamharia, Jamshedpur through its Director, Sudhir Rai ..... … Petitioner 25 Versus 1. The State of Jharkhand, through the Secretary, Finance Department, Project Building, Dhurwa, Ranchi 2. The Commissioner of Commercial Taxes, Project Bhawan, Dhurwa, Ranchi 3. Joint Commissioner of Commercial Taxes (Administration), Jamshedpur, Division, Jamshedpur. 4. Deputy Commissioner of Commercial Taxes, (Adityapur Circle), Jamshedpur 5. Assistant Commissioner

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

vi) Bank account of the plaintiff/Company in the Citibank showing an amount therein of Rs.5.50 crores as on 26.4.2007, Ex.PW2/1. (vii) The empty (as alleged by plaintiff) envelope sent by the defendant no.2 to the plaintiff as Ex.PW-1/8/Ex.P-11. CS(OS) No. 78/2007 Page 6 of 43 (viii) Envelope in which as per the plaintiff new year greetings were

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. In order to make the sale, as one in the course of inter-State trade or commerce, there must be an obligation to transport the goods outside the State. [Shankerjee Raut Gopalji Raut43; Bhag Singh Milkha Singh4; Ben Gorm Nilgiri Plantations Co. Coonoor (Nilgiris)41]. A sale, by definition, being transfer of property became taxable under Section

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

VI. Duty of Division Bench in LPA to decide on facts if Single Judge's order in substance falls under Art. 226, wholly or partially - Division Bench to which LPA is made, is required to ascertain whether facts justify assertions made in writ petition to invoke jurisdiction under Art. 227 or 30 LPA-22-2008+ Art. 226 or under both/whether

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

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 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 IV vs. M/s. Nava Bharat Ferro Alloys Ltd.,

ITTA/392/2013HC Telangana05 Sept 2013
Section 14Section 14(1)(e)

36; Mussauddin Ahmed Vs. State of Assam (2009) 14 SCC 541; Pradip Buragohain Vs. Pranati Phukan (2010) 11 SCC 108; Freddy Fernandes Vs. P.L. Mehra 1973 RCR 53; State of W.B. Vs. MIR Mohammadomar & Ors. (2000) 8 SCC 382; Grand Vasant Residents WEL. ASS. Vs. DDA 2014 (4) AD (delhi) 193; State of U.P. Vs. Nahar Singh (Dead

COMMISSIONER OF INCOME TAX RAJAHMUNDRY vs. M/S.B.KRISHNA MURTHY KAKINADA AND 2 ORS

ITTA/93/2002HC Telangana10 Dec 2013

Bench: CHALLA KODANDA RAM,G.CHANDRAIAH

Section 260A

Section 9(1)(vi) of the Act, but the term “royalty” as defined and covered under Art VIII A of the DTAA. 7. Before we examine the relevant clauses of agreement dated 11th May, 1987 between HCL and ADC, it would be first appropriate to examine the ambit and scope of the term „royalty‟ taxable under Article VIIIA

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

1 SCC 243 - 22 - RFA No.178 OF 2015 C/W RFA CROB NO.19 OF 2015 novation or not, depends on the intention of parties, as seen from the substance of the agreement and not merely from its form. If there is no intention to rescind the prior arrangement altogether, there is no substitution, and the original contract still remains enforceable. This

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