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32 results for “transfer pricing”+ Section 49(1)clear

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Key Topics

Section 26010Addition to Income10Section 260A9Section 965Section 9(1)(vi)5Section 13(1)(e)4Section 44Section 1514Section 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)

49 / 79 CRA-322-08gr defendant no.2 did not establish payment of deposit, payment of compensation as also his exclusive possession in the suit premises, defendant no.2 cannot avail benefit of Section 15A. The findings recorded by the Appellate Court are perverse. In fact, the findings recorded by the appellate court outrageously defy logic as to suffer from

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 32 · Page 1 of 2

4
Capital Gains3
Deduction2
Double Taxation/DTAA2
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

M/S.R.S.RANGADAS vs. THE ASST.COMMISSIONER OF INCOME TAX

Appeals are disposed of, with no order as to costs

ITTA/406/2005HC Telangana19 Oct 2022

Bench: C.V. BHASKAR REDDY,UJJAL BHUYAN

Section 2(47)Section 271(1)(c)Section 45(1)Section 48Section 54F

49,680/- vide revised return filed on 29th June, 1999. 4. For the AY 1999-2000, the assessee had filed its return of income on 29th June, 1999 declaring income of Rs.24,24,010/-. 5. In the returns of income for the AY 1998-99, under the head „long term capital gain‟ the assessee had disclosed transfer consideration of Rs.5

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

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

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

49. Section 3 of the Services Contract which provide for the scope of work and services to be performed under the Service Contract and the relevant extracts from the said section are reproduced below:- ―3.1.1 The Vendor has to provide to Reliance the Services set forth in the relevant Purchase Order pursuant to and in accordance with this Optical Services

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

transfer at Jagdalpur, he handed over the further investigation to Sahid Ali / P. K. Shukla under the instruction of Superintendent of Police. In cross-examination he admitted that he has not 13 come across about any circular that 60% of the total amount is to be considered as expenditure and 40% is to be considered as savings. He further admitted

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

ITTA/249/2013HC Telangana11 Jul 2013
Section 4

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-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

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

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

price paid or promised or part- paid and part-promised. Sale how made.—Such transfer, in the case of tangible immoveable property of the value of one hundred rupees and upwards, or in the case of a reversion or other intangible thing, can be made only by a registered instrument. 1In the case of tangible immoveable property of a value

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

1 making appellants and the erstwhile tenant of the land, as parties. 43 LPA-22-2008+ The matter with regard to declaration had been sought to be litigated by respondent himself while there had been no declaration and realizing that other persons interest had been created and subsisting and as such would be required to be heard. The corollary

The Commissioner of Income Tax (IT and TP) vs. M/s. Idea Cellular Limited

Accordingly, the learned appellate authority has rightly dismissed the

ITTA/14/2021HC Telangana19 Oct 2023

Bench: P.SAM KOSHY,LAXMI NARAYANA ALISHETTY

Section 107

49. 19. The Input Tax Credit is a nature of benefit or concession extended to the dealer under the statutory scheme. The concession can be received by the beneficiary only as per the scheme of the statute. 20. In the matter of Godrej & Boyce Mfg. Co. Pvt. Ltd. and others v. Commissioner of Sales Tax and others14, their Lordships

Suchirindia Infratech Pvt. Ltd vs. Dy. Commissioner of Income-Tax

Accordingly, the learned appellate authority has rightly dismissed the

ITTA/15/2021HC Telangana30 Apr 2021

Bench: T.VINOD KUMAR,M.S.RAMACHANDRA RAO

Section 107

49. 19. The Input Tax Credit is a nature of benefit or concession extended to the dealer under the statutory scheme. The concession can be received by the beneficiary only as per the scheme of the statute. 20. In the matter of Godrej & Boyce Mfg. Co. Pvt. Ltd. and others v. Commissioner of Sales Tax and others14, their Lordships

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

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)

49 DRJ 717 held: “Let us examine the plea of petitioner in the application for leave to defend. A statement made in the counter affidavit that the owner while staying in U.S.A. and the income of the husband of the owner-landlady was enormous and they are accustomed to the lifestyle of U.S.A. and respondent was only coming

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

ITTA/549/2011HC Telangana21 Apr 2025

Bench: P.SAM KOSHY,NARSING RAO NANDIKONDA

Section 260Section 28

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

M/s. Maruthi Movies vs. Income Tax Officer

ITTA/486/2011HC Telangana04 Jul 2012

Bench: This Court & Making The Same A Rule Of Court, Alongwith Decree Against Respondents Awarding Rs.5,35,920/- Paid By The Petitioner To The Arbitrator As Their Share Of Fees As Per Order Dated 21.12.2010. 2. Respondent No.1 Has Filed Its Objections To The Award Under Section 30 & 33 Of The Act In Form Of I.A. No.9067/2011. Respondent No.2 Has Also Filed Its Objections To The Award.

Section 20Section 30

49. Relying upon the judgment of the Karnataka High Court in Robert D’Silva v. Roshini Enterprises and Another, 1986 SCC OnLine Kar 3, he submits that the bar to enforcement of contracts based on volition of parties contained in Section 14(1)(b) of the Specific Relief Act before amendment only applies to Contracts of personal services and merely

Commissioner of Income Tax-1 vs. Agricultural Market Committee

ITTA/186/2011HC Telangana21 Apr 2011

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

Section 151Section 96

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