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40 results for “transfer pricing”+ Section 43(6)clear

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Key Topics

Section 26012Section 260A11Addition to Income11Section 809Section 8O8Section 965Section 9(1)(vi)5Section 13(1)(e)4Section 4

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

ITTA/537/2015HC Telangana02 Nov 2015

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Section 260

6. We are in general agreement with the view taken by the Madras High Court and we think that while the view taken by the Bombay High Court is rather narrow the one taken by the former High Court of Nagpur is too wide. The proper test for determining whether a question of law raised in the case is substantial

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

43. With great respects, we may only observe and as we have held in the case of Heirs of Deceased Jethabhai Ishwarbhai (Supra), decided on 22.1.2021, that Section 10(6) of the ULC Act does not envisage the issuance of any Notice at all and nor the judgement of the Supreme Court in the case of Bhaskar Jyoti Sarma (Supra

Showing 1–20 of 40 · Page 1 of 2

4
Survey u/s 133A3
Deduction3
Double Taxation/DTAA2

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

ITTA/455/2017HC Telangana06 Jul 2017

Bench: SANJAY KUMAR,GUDISEVA SHYAM PRASAD

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 Banerjee, learned Sr. Standing Counsel-III have opposed the prayer made in the writ applications and have contended that the impugned amendments made under

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

ITTA/134/2016HC Telangana14 Jul 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

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 Banerjee, learned Sr. Standing Counsel-III have opposed the prayer made in the writ applications and have contended that the impugned amendments made under

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 per acre (4 bighas 16 biswas or 4,840 sq yds) being 1,25,25,000/-. Plaintiff under the two Agreements to Sell dated 25.9.2006 paid a sum of Rs.40 lacs. A further amount of Rs.13 lacs was paid by the plaintiff to the defendants on 5.10.2006 which was acknowledged by means of a Receipt dated 10.10.2006. In terms

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

Commissioner of Income Tax-II vs. M/s.Jayalakshmi Chits

ITTA/211/2008HC Telangana23 Mar 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

43,750/­ c) 30,000 12,22,500 19.2.92 40.75 28 L & T 19,45,000 18.2.92 a) 10,000 194.50 21,30,000 b) 5,000 9,35,000 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

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

43,750/­ c) 30,000 12,22,500 19.2.92 40.75 28 L & T 19,45,000 18.2.92 a) 10,000 194.50 21,30,000 b) 5,000 9,35,000 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

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

43,750/­ c) 30,000 12,22,500 19.2.92 40.75 28 L & T 19,45,000 18.2.92 a) 10,000 194.50 21,30,000 b) 5,000 9,35,000 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

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

43, 45, 69, 75, 77, 88 and 89, no document shall be registered under this Act, unless the persons 64 executing such document, or their representatives, assigns or agents authorized as aforesaid, appear before the registering officer within the time allowed for presentation under sections 23, 24, 25 and 26: Provided that, if owing to urgent necessity or unavoidable accident

Commissioner of Income Tax vs. Sri. B. Venkatesam,

The appeal stands disposed of with no order as to

ITTA/41/2000HC Telangana01 Dec 2011
For Appellant: Mr C.S. Aggarwal, Sr. Advocate withFor Respondent: Mr Sanjeev Sabharwal, Sr. Standing Counsel
Section 260A(1)Section 43B

6 of 24 customs duty on the CIF value of imported material. The said additional demand was challenged by the importers before the Supreme Court in Writ Petition (Civil) No.15220-22/1984. The Supreme Court allowed the clearance of imported material on payment of 15% of the disputed additional custom duty and granted stay for balance 85% of the said duty, pending

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

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

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

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

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)

43 / 79 CRA-322-08gr contemplated by Section 13(1)(e) and non user as contemplated by Section 13 (1)(k) of the Act. 59. Plaintiffs have contended that defendant no.1 has, since coming into operation of the Act, unlawfully sub-let or given on leave and licence, the whole or part of the suit premises or assigned

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

6 of the decision of supreme court in the case of Jogendrasinhji Vijaysinghji Vs. State of Gujarat and others reading, thus, “ A. Courts, Tribunals and Judiciary - High Courts - Letters PatentAppeal - When maintainable before Division Bench of High Court against orders of Single Judge of High Court issued in exercise of writ jurisdiction - Principles summarised - Duties of Appellate Bench of High

Principal Commissioner of Income Tax - 5 vs. M/s Vijay Textiles Limited

The appeal is dismissed

ITTA/541/2015HC Telangana16 Feb 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Section 167BSection 2(31)Section 2(47)Section 260Section 3Section 4Section 67A

6 hereof. 8.3 The amount payable to the First Party under Article 8.1 be paid together with the sale price of the land after the completion of each phase of the development in all respects as per the statement of accounts duly audited by a reputed firm of Chartered Accountants appointed by the Second Party. ARTICLE 9 For the purpose

THE COMMISSIONER OF INCOME TAX-IV, HYDERABAD vs. M/S NAVA BHARAT VENTURES LTD., HYDERABAD

ITTA/251/2014HC Telangana18 Jun 2025

Bench: P.SAM KOSHY,NARSING RAO NANDIKONDA

For Respondent: C V NARA
Section 260Section 260ASection 80Section 8O

transferred from Power recovery rate of Power and ed by AP TRANSCO from at the power generattng at rates varying between er contended that the CIT(A) 5 Itta 251 2014 entitled to avail deduction under Section 8O-I of the Act, 196 1 on the proht earned from the captive consumption power plant' Though the CIT has not accepted

THE COMMISSIONER OF INCOME-TAX-IV, HYDERABAD vs. M/S NAVA BHARAT VENTURES LTD., HYD

The appeal is dismissed

ITTA/579/2016HC Telangana20 Jun 2025

Bench: P.SAM KOSHY,NARSING RAO NANDIKONDA

Section 260Section 260ASection 80Section 8O

transfer red from power unit to ferro is to be charged with recovery ra-e of power and not at wt.ich the power purchased by AP 'IRANSCO from assessee. He further argued that the power generating companies are supplying power at rates vrrrying between Rs.2.21 to 3.15 per unit. He further contended that the CIT(A) agreed

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

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

43. It is apparent from the plain reading of Section 9(1) of the Act that all income which accrues or arises through or from any business connection in India would be deemed to accrue or arise in India. In CIT v. R.D. Aggarwal & Co.: (1965) 56 ITR 20 (SC), the Supreme Court observed that business connection would mean