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45 results for “transfer pricing”+ Section 41(1)clear

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Key Topics

Addition to Income13Section 26012Section 260A11Section 968Section 1517Section 9(1)(vi)5Section 13(1)(e)4Section 44Section 21

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)

41 / 79 CRA-322-08gr read with 108(o) of the T.P.Act is concerned, the evidence of PW 4 Powale, Structural Engineer and the reports made by him at Exhibit -H, remained absolutely unchallenged. The Courts below after appreciating the evidence on record have concurrently held that defendant no.2 has carried out additions and alterations of permanent nature

Principal Commissioner of Income Tax-3 vs. M/s Satyasai Bhavani Hsopitals Private Limited

ITTA/537/2015HC Telangana02 Nov 2015

RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Showing 1–20 of 45 · Page 1 of 3

4
Survey u/s 133A4
Capital Gains2
Deduction2
Bench:
Section 260

1) (d) of the Act. Section 254 of the Act empowers the Appellate Tribunal to pass such orders on the appeals ‘as it thinks fit’ after giving an opportunity of hearing to both the parties. 38. From the aforesaid Scheme of assessment with regard to international transactions, it is clear that the process of determination of ‘Arm’s Length Price

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 (Central) vs. Madhu Enterprises

ITTA/455/2017HC Telangana06 Jul 2017

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,

ITTA/134/2016HC Telangana14 Jul 2016

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-V vs. The Armed Forces Officers Co.Op Housing Society Ltd

ITTA/78/2007HC Telangana27 Aug 2011

Bench: CHALLA KODANDA RAM,G.CHANDRAIAH

Transfer) Act, 1972, but the defendants failed to do so and defendants were not in a position to execute the sale deeds in the absence of such NOC, it is thus held that the defendants were guilty of breaches of contracts being the Agreements to Sell dated 25.9.2006 and not the plaintiff. Issue no.5 is therefore, decided in favour

M\S.CHENNAKESAVA VIJAYAWADA vs. THE COMMISSIONER OF INCOME TAX VIJAYAWAD

The Appeal is dismissed

ITTA/33/2000HC Telangana27 Aug 2012

Bench: GODA RAGHURAM,M.S.RAMACHANDRA RAO

Section 194CSection 197(1)Section 201

1,84,41,814/=. The appellant-Company, while submitting a letter dated 18th May 1998 providing the details of payments made to Messrs. Essar Projects Limited, made a mention of payment made towards procurement of material to the tune of Rs. 72.60 Crores. The I.T.O with regard to the supply of these materials, discussed the issue in its order

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

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

41. In the aforesaid context, it would be appropriate to assume that the Equipment Contract was performed by Nortel Canada - as has been held by the AO and CIT(A) and concurred with by the ITAT - and on that footing, it is to be examined whether any income from supply of equipment could be taxed under the Act. 42. Section

Commissioner of Income Tax, vs. M/s Y.Ramakrishna and others

ITTA/172/2003HC Telangana21 Jun 2011

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

Section 1Section 151Section 96

41 Rule 1 of C.P.C., aggrieved by the Judgment and decree dt- 21-11-2002 passed in O.S.No.96 of 1999 on the file of V Addl. District Judge, Fast Track Court, Ranga Reddy Dist., L.B. Nagar. Between: 1. V.SURENDER REDDY, S/o late Sri V. Gopal Reddy Business Rl/o Road No.10, Banjara Hills. Hyderabad 2. D. Madhav

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

41. PW-30, Sahid Ali is the Inspector of Lokayukta Police, Raipur he proved the document Ex.P/89 which is warrant issued by the Court for search of the house of the appellant. He searched the house of the appellant on 20.12.1994 along with the search party and prepared the seizure memo Ex.P/5. The panchnama Ex.P/4 was also prepared

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

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

1 - K.T.Plantation Private Limited & Anr. Vs. State of Karnataka”. 95. As discussed above, with reference to Section 54 of the Transfer of Property Act, the sale of immoveable property worth 100 or more than 100 is to be effected through registered document which invariably supposes that it shall be in writing and 90 sufficient non judicial stamp shall be required

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

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

41 of films and other activities connected with the examination, repairs, cleaning, waxing and rewinding of the films.” It was argued before the Supreme Court that section 10 could not be applied as the assessee could not be said to be in occupation of the premises for the purposes of any concern of its own, but it was observed

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-III vs. Smt. Raj Kumari

Accordingly are partly allowed

ITTA/23/2008HC Telangana28 Mar 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

41 LPA-22-2008+ consideration. 45. Perusal of order passed by commissioner under section 98 proceeding would show that the only consideration which has weighed with him is order dated 15-02-2006 passed in revision bearing no. 71/B/2002/Osmanabad whereas the deputy collector has considered that appellant no. 1 being female, cannot demand partition. This assumption despite the decree

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

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

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

price, but instead of getting a deed of conveyance gets a SA/GPA/WILL as a mode of transfer, either at the instance of the vendor or at his own instance. Ill - effects of SA/GPA/WILL transactions: Page 41 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. 3. The earlier order