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107 results for “transfer pricing”+ Section 5clear

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Key Topics

Section 26063Section 8032Addition to Income31Section 260A28Section 10A27Transfer Pricing21Deduction19Comparables/TP19Section 96

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

5) of the Act also being subject to appeal under Section 33 of the Act is an obiter of the learned Single Judge which is clearly contrary to the decision of Full Bench of this Court in Shah Jitendra Nanalal (supra). Therefore, it has to be treated as impliedly overruled and no longer a good law. We need not express

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

Transfer Pricing Officer (TPO) or Dispute Resolution Panel (DRP) which comprises of three Commissioners and the Revenue or the assessee may feel dissatisfied, because of the reversal or modification of such findings by the Tribunal resulting in leaving out of certain comparables or adding on of certain comparables for determining the ‘Arm’s Length Price’ in the hands

Showing 1–20 of 107 · Page 1 of 6

11
Survey u/s 133A10
Section 80H9
Section 1519

M.Y.Maharshi vs. The Asst. Commissioner of Income-Tax

In the result, we do not find

ITTA/282/2013HC Telangana16 Jul 2013
Section 10ASection 143(1)Section 143(2)Section 260Section 92C

5 (Appeals), Bangalore-I, Bangalore, a reference was made to the Transfer Pricing Officer to determine the arms length price as per Section

The Commissioner of Income Tax vs. M/s.Sri Lakshmi Narasimha Construction

ITTA/211/2006HC Telangana21 Mar 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Section 247Section 98

5 of the Hyderabad Tenancy and Agricultural Lands Act, 1950, there is no bar to lease the immovable property within the relations in terms of the provisions of Chapter V (Sections 105 to 117) of the Transfer of Property Act, 1882. I have given my thoughtful consideration to these submissions made on behalf of the petitioners. In terms

THE PRL COMMISSIONER OF INCOME TAX-II, VISAKHAPATNAM vs. L SURYAKANTHAM, VISAKHAPATNAM

In the result, the appeal fails and is hereby dismissed

ITTA/285/2017HC Telangana08 Oct 2018

Bench: RAMESH RANGANATHAN,KONGARA VIJAYA LAKSHMI

Section 143(2)Section 14ASection 260Section 80JSection 92C

transfer pricing Rs.20,20,07,861/-, disallowance under Section 14A read with Rule 8D(2)(iii) to the extent of Rs.20,51,175/- and disallowance of Rs.74,08,964/- under the provisions of Section 80JJAA of the Act were proposed. The 5

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

5) and 3(15) of the Act and which Sections show that once an area falls within a town area and an area ceases to be an agricultural land because it has to be developed as part of the development of the Delhi town or New Delhi town, then such an area no longer remains an agricultural area for being

Commissioner of Income Tax, vs. Agricultural Market Committee,

ITTA/251/2008HC Telangana01 Mar 2011

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

For Respondent: Ms. K.Lalitha, Standing Counsel for
Section 10(20)Section 10(29)Section 12ASection 260ASection 4Section 4(1)

Transfer of Undertakings) Act, 1980 or any other bank being a bank included in Second Schedule to Reserve Bank of India Act, 1934 and the like. The breach of Section 11(5) would attract Section 13(1)(d) of the IT Act and the benefit under Sections 11 and 12 would not be available if funds are deposited or invested

Commissioner of Income Tax, Guntur. vs. Agricultural Market Committee, Kangiri.

ITTA/318/2008HC Telangana01 Mar 2011

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

For Respondent: Ms. K.Lalitha, Standing Counsel for
Section 10(20)Section 10(29)Section 12ASection 260ASection 4Section 4(1)

Transfer of Undertakings) Act, 1980 or any other bank being a bank included in Second Schedule to Reserve Bank of India Act, 1934 and the like. The breach of Section 11(5) would attract Section 13(1)(d) of the IT Act and the benefit under Sections 11 and 12 would not be available if funds are deposited or invested

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

price in September, 1998, they would have exceeded the purchase value of the immovable property 5, Golf ITA Nos. 405/2005, 406/2005 & 389/2007 Page 5 of 26 Links, New Delhi of Rs.10.75 Crores. During the AY 1999-2000, the assessee had sold 65,552 equity shares of NIIT to M/s GIPL on 2nd April, 1998 for Rs.5,89,96,800/- resulting

M/S VAIBHAV vs. JOINT COMM. OF INCOME TAX RANGE 3 HYD

Appeal is allowed and the judgments and decrees passed by the

ITTA/58/2002HC Telangana14 Sept 2022

Bench: The Learned Trial Court) Was Allowed & The Judgment & Decree Dated 12.12.2000, Passed By Learned Senior Sub Judge, Kullu Was Set-Aside. (Parties Shall Hereinafter Be Referred To In

For Appellant: Mr. Bimal Gupta, Sr. Advocate with

Section 55 (4) (b) of the Transfer of Property Act which are set out below:- "55. In the absence of a contract to the contrary the buyer and seller of immovable property respectively are subject to the liabilities, and have the rights, mentioned in the rules next following, or such of them as are applicable to the property sold

The Commissioner of Income Tax (Central) vs. Akula Nageswara Rao

In the result, the orders passed by the Assessing

ITTA/422/2017HC Telangana10 Jul 2017

Bench: SANJAY KUMAR,GUDISEVA SHYAM PRASAD

Section 39(1)Section 5Section 65(1)Section 9(2)

price as well as the terms and conditions. The aforesaid quotation states that Dell product would be exported from Malaysia. Thus, the petitioner seeks customer's upfront contractual approval of manufacture and supply of required product from Malaysia. On receipt of the quotation, customer accepts either by signing the same or by raising a purchase order or by making

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

ITTA/455/2017HC Telangana06 Jul 2017

Bench: SANJAY KUMAR,GUDISEVA SHYAM PRASAD

price of goods taxable under Section 10 of the CST Act; ii) Transaction falling under Section 5(2), Section 6-A and Section 6(2) of the CST Act, 1956, iii) Value of transfer

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

ITTA/134/2016HC Telangana14 Jul 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

price of goods taxable under Section 10 of the CST Act; ii) Transaction falling under Section 5(2), Section 6-A and Section 6(2) of the CST Act, 1956, iii) Value of transfer

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

5) Nothing in this section applies to copies of decrees or orders. State Amendments Tamil Nadu: In section 34,— (1) in sub-section (1), after the expression “persons executing such document”, the expression “and in the case of document for sale of property, the persons claiming under that document” shall be inserted; (2) in sub-section (3), in clause

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-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-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

5 - OSA No. 19 of 2015 be, shall take into his custody or under his control, all the properties, effects and the actionable claims to which the Company is or appears to be entitled." 6. Further Section 456(2) provides "All the properties and effects of the Company shall be deemed to be in the custody of the Tribunal

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

transfer to other entities. In terms of the application made to RBI and permission obtained, the liaison office was to act as a communication channel between the head office and the customers in India. The assessees did not file returns of income for any year. 5. A survey under Section 133A of the Act was conducted