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

The Commissioner of Income Tax-IV vs. M/s Pokarna Limited

The appeals are dismissed

Bench: P.SAM KOSHY,NARSING RAO NANDIKONDA

price received by the respondent was at the rate of Rs.136 per share the full value of the consideration must be taken at the rate of Rs.136 per share. The view that we have expressed as to the interpretation of the main part of section 12B(2) is borne out by the fact that in the first proviso to section

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

48. Now the next aspect that has come up for consideration before this Court in this case is regarding the registration and consequences of refusal to register. In this connection, Sections 73, 74 and 75 49 of the Indian Registration Act, indicate the formalities. 49. When the execution is denied by the seller after completing formalities of execution

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

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

48 YEARS, R/O NO.1399, 12-B, CROSS ROAD, II STAGE, BASAVESWARANAGAR, BANGALORE-560 096. ...CROSS OBJECTOR (BY SRI.JAYAKUMAR S PATIL., SENIOR COUNSEL A/W SRI.H N BASAVARAJU., ADVOCATE) AND: 1 . M/S SUN RAMA EXPORTS PRIVATE LTD., A COMPANY REGISTERED UNDER THE INDIAN COMPANIES ACT,1956 HAVING ITS REGISTERED OFFICE AT SANJAY PLAZA,6TH FLOOR, A.B.NAIR ROAD, JUHU, MUMBAI-400049. REPRESENTED HEREIN

The Pr. Commissioner of Income-tax vs. D.L.V. Sridhar

Bench: D.V.S.S.SOMAYAJULU,RAMESH RANGANATHAN

Transfer Pricing Officer had not verified whether the expenditure claimed was correct. Recording the aforesaid findings, the Assessing Officer disallowed the entire claim of Rs.1,48,89,090/- under section

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

The appeal is dismissed

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

price of Rs.150/- sq.ft for the land has been fixed, but land was the capital to be introduced by the 32 assessee for the purpose of endeavor. That assessee had considerable stake, is clear from the fact that asseessee was obliged to offer the land as security for raising loans. Assessee had parted with possession with clear knowledge that

The Commissioner of Income Tax (Central) vs. M/s Hyderabad House Pvt Ltd.,

price index for industrial workers [CPI (IW)]. The view in Kamla Devi (supra) was followed in a number of subsequent decisions of this Court in cases reported as Ashwani Gupta v. Government of India & Ors. 117 (2005) DLT 112; Tasleema v. State (NCT of Delhi) & Ors. ILR (2009) 6 Del 486 : (2009) 161 DLT 660 (DB); Nagrik Sangarsh Samiti

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

The Appeal is dismissed

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

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

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

Accordingly are partly allowed

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

48. Hasan Bin Salam V. Madhavrao (supra) was a case wherein the respondent had been declared as owner under section 38E and that he had deposited the price of the land. In the circumstances, the ownership had been statutorily transferred

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

Bench: SANJAY KUMAR,GUDISEVA SHYAM PRASAD

price of goods taxable under Section 10 of the Act; ii) Transaction falling under Section 5(2), Section 6-A and Section 6(2) of the CST Act, 1956, iii) Value of transfer of a business as a whole iv) [ xxx] (iii) This sub-rule is not applicable, if the VAT dealer is making exempt transactions. 22. By comparing

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

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

price of goods taxable under Section 10 of the Act; ii) Transaction falling under Section 5(2), Section 6-A and Section 6(2) of the CST Act, 1956, iii) Value of transfer of a business as a whole iv) [ xxx] (iii) This sub-rule is not applicable, if the VAT dealer is making exempt transactions. 22. By comparing

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

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

48 / 79 CRA-322-08gr admission of leave and licence agreement dated 1.7.1970 between defendant no.1 and defendant no.2 in respect of the suit premises. The Appellate Court further observed that the plaintiffs admit not only the execution of the said agreement but also admit that atleast before 1972 the suit premises were occupied by defendant no.2

COMMISSIONER OF INCOME TAX-III, HYD vs. M/S. SUJANA METALS LTD, HYD

Bench: P.SAM KOSHY,NARSING RAO NANDIKONDA

price; and (ii) In any other case [not being a case falling under sub-clauses (i) to (iv) of sub-section (1) of section 49], shall be taken to be nil” ITA 549/2011 Page 11 of 16 9. This provision clearly provides determining the cost of any relation to a capital asset being the right to manufacture, produce or process

Commissioner of Income Tax-1 vs. Agricultural Market Committee

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

transfer is, therefore, not vitiated by lis pendence. Section 52 of the Act does not wipe out the transaction altogether. 5.PrinciplegroundsofcontentioninC.C.C.A.No.186 of 2O11 are as under:- TheLowerCourtfailedtoseethatRespondentsl to 11 and 14 (Vendors) failed to comply with the condition of obtaining NOC under IT Act, which was mandatory on the date of the agreement of sale Ex. A3 and filing

Commissioner of Income Tax vs. Agrilcultural Market Committee

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

transfer is, therefore, not vitiated by lis pendence. Section 52 of the Act does not wipe out the transaction altogether. 5.PrinciplegroundsofcontentioninC.C.C.A.No.186 of 2O11 are as under:- TheLowerCourtfailedtoseethatRespondentsl to 11 and 14 (Vendors) failed to comply with the condition of obtaining NOC under IT Act, which was mandatory on the date of the agreement of sale Ex. A3 and filing