The Commissioner of Income Tax-II, vs. M/S Gulf Oil Corporation Pvt. Ltd.,

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

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

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

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

Commissioner of Income Tax vs. Sri Chirla Rama Reddy, Contract

Appeal is dismissed with costs

Bench: The Hon’Ble Mr. Justice N.K.Sudhindrarao R.S.A.No.70/2007

price for sale of property sold by her husband which is western portion of Tataguni estate in favour of plaintiff-Company and she has not agreed to sell the plaint schedule property to the plaintiff at the rate of Rs.40,000/- per acre. 17. It is further claimed that Managing Director of plaintiff-Company K.T. Bhagath was with

The Commissioner of Income Tax-V vs. The Armed Forces Officers Co.Op Housing Society Ltd

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

Bench: P.SAM KOSHY,NARSING RAO NANDIKONDA

37 depend upon the object with which the act is done. It is not that no company can own property and enjoy it as property, whether by itself or by giving the use of it to another on rent. Where this happens, the appropriate head to apply is “income from property” (section 9), even though the company may be doing

The Commisioner of Income TAx-1 vs. Divya Shakti Granites Ltd.,

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

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

THE COMMISSIONER OF INCOME TAX, VIJAYAWADA vs. M/S. PADMAVATHI MANSION (P) LTD., VIJAYAWADA

Bench: C.V.NAGARJUNA REDDY,T.AMARNATH GOUD

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

PR COMMR OF INCOME TAX-2, HYDERABAD vs. K RAVINDER REDDY, HYDERABAD

Bench: RAMESH RANGANATHAN,KONGARA VIJAYA LAKSHMI

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 Commissioner of Income Tax-III vs. Smt. Raj Kumari

Accordingly are partly allowed

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-IV, vs. M/s. Mahaveer Enterprises (India) Limited

The Appeal is dismissed

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

37 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. The said judgement of the learned Single Judge also, in our opinion, is distinguishable as the delay in the present case was not a minor delay but a huge delay of 2 years and 3 months and no sufficient

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

Bench: SANJAY KUMAR,GUDISEVA SHYAM PRASAD

price of goods. The manner of 49 calculation of ITC was entirely different before this amendment. In the example, which has been given in the earlier part of the judgment, “dealer” was entitled to ITC of Rs. 10 on resale, which was paid by the dealer as VAT while purchasing the goods from the vendors. However, in view of Section

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

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

price of goods. The manner of 49 calculation of ITC was entirely different before this amendment. In the example, which has been given in the earlier part of the judgment, “dealer” was entitled to ITC of Rs. 10 on resale, which was paid by the dealer as VAT while purchasing the goods from the vendors. However, in view of Section

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

transfer of property became taxable under Section 3(a) if the movement of goods from one State to another was under a covenant, or an incident, of the contract of sale and the property in the goods passed to the purchaser in another State. [S.R. Sarkar26]. If there was interruption of movement, and the snapping of the inextricable bond that

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

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

37 / 79 CRA-322-08gr respect of the same. Ultimately in paragraph 88, the Appellate Court observed that the evidence on record shows that additions and alterations of permanent nature were carried out in the suit premises in the year 1990 and the same are attributable to defendant no.2. 49. Mr. Walawalkar submitted that the Courts below failed

The Commissioner of Income Tax vs. M.Venkata Krishna Mohan

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

37(1) of the Act in respect of payment of Rs.1 Crore made to HRL for use of Trade Mark under the second license agreement. Assessment was completed under Section 143(3) of the Act and the income of the appellant was determined at Rs.84,95,035/-. The assessing Officer (hereinafter „AO‟) came to the conclusion that since the payment

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

Bench: C.V. BHASKAR REDDY,UJJAL BHUYAN

37 + ITA 220/2023 THE COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-1, NEW DELHI .....Appellant Through: Mr. Puneet Rai, SSC with Mr. Ashvini Kr., Mr. Rishabh Nangia, JSCs, Mr. Nikhil Jain Digitally Signed By:KAMLESH KUMAR Signing Date:17.02.2025 14:23:05 Signature Not Verified ITA 202/2022 & Connected Matters Page 4 of 22 and Ms. Srishti Sharma, Advs. versus EXPEDITORS INTERNATIONAL