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28 results for “transfer pricing”+ Section 63clear

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Key Topics

Section 260A10Section 10(20)10Section 80P(2)(a)8Exemption7Section 12A6Deduction6Addition to Income5Section 464Section 2604

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

63,10,300/- as per return for the AY 1998-99 and any profit in future on sale of the transferred NIIT shares would be adjusted against this accumulated book loss. 8. Assessment Order records that to investigate, whether this was a case of legitimate tax planning or tax evasion and whether the transaction was genuine, notices under Section

Commissioner of Income Tax vs. Sri Chirla Rama Reddy, Contract

Appeal is dismissed with costs

Showing 1–20 of 28 · Page 1 of 2

Section 44
Section 10(29)4
Business Income4
ITTA/70/2007HC Telangana23 Mar 2016

Bench: The Hon’Ble Mr. Justice N.K.Sudhindrarao R.S.A.No.70/2007

Section 100

Section 54 of the Transfer of Property Act, as under: “Sale” defined.—‘‘Sale” is a transfer of ownership in exchange for a 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

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)

price paid or promised, or of money, a share 57 / 79 CRA-322-08gr of crops, service or any other thing of value to be rendered periodically or on specified occasions to the transferor by the transferee, who accepts the transfer on such terms. Relying upon this judgment as also Section 105 of T.P. Act he submitted that leave

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 (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

63) of Section 2 of the CGST Act defines, “input tax credit” means the credit of input tax. Chapter V of the CGST Act deals with Input Tax Credit. Section 16 of the CGST Act Page 15 of 32 {W.P.(T)Nos.14/2021, 15/2021, 16/2021, 17/2021 & 18/2021} provides for Eligibility and conditions for taking input tax credit. Sub-section

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

63) of Section 2 of the CGST Act defines, “input tax credit” means the credit of input tax. Chapter V of the CGST Act deals with Input Tax Credit. Section 16 of the CGST Act Page 15 of 32 {W.P.(T)Nos.14/2021, 15/2021, 16/2021, 17/2021 & 18/2021} provides for Eligibility and conditions for taking input tax credit. Sub-section

The Pr. Commissioner of Income Tax-2 vs. M/s. GJ Trading Pvt Ltd

ITTA/246/2022HC Telangana05 Sept 2022

Bench: C.V. BHASKAR REDDY,UJJAL BHUYAN

Section 9(1)(vii). Hence, we hereby decline to interfere with the directions of the Dispute Resolution Panel in this case.” 6. Before us Mr. Rai, learned counsel for the appellant, however, would submit that as per the disclosures which were made by the assessee in the Transfer Pricing Study itself, the transaction relating to Freight Logistic Support Services would

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)

63, the following income shall not be included in the total income of the previous year of the person in receipt of the income— (a) income derived from property held under trust wholly for charitable or religious purposes, to the extent to which such income is applied to such purposes in India; and, where any such income is accumulated

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)

63, the following income shall not be included in the total income of the previous year of the person in receipt of the income— (a) income derived from property held under trust wholly for charitable or religious purposes, to the extent to which such income is applied to such purposes in India; and, where any such income is accumulated

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

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 RAJAHMUNDRY vs. M/S.B.KRISHNA MURTHY KAKINADA AND 2 ORS

ITTA/93/2002HC Telangana10 Dec 2013

Bench: CHALLA KODANDA RAM,G.CHANDRAIAH

Section 260A

Section 9(1)(vi) of the Act, but the term “royalty” as defined and covered under Art VIII A of the DTAA. 7. Before we examine the relevant clauses of agreement dated 11th May, 1987 between HCL and ADC, it would be first appropriate to examine the ambit and scope of the term „royalty‟ taxable under Article VIIIA

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

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

Section 1. Assignment and Assumption. Assignor hereby assigns to the Assignee all the rights, entitlements, covenants and obligations of the Assignor under the Equipment Contract to sell, supply and deliver the Equipment to the Purchaser under the Equipment Contract and the Assignee hereby assumes, and agrees with all of the parties hereto, to perform, observe and be bound by each

The Commissioner of Income Tax-II vs. The Andhra Bank Employees Co.Operative Bank Limited

In the result, for the above reasons, these appeals fail and

ITTA/243/2007HC Telangana07 Jun 2011

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

Section 260ASection 46Section 80P(2)(a)

transfer to the reserve fund a sum equivalent not less than 20% of such profit. Further, under Section 18 of the BR Act, every banking company, not being a scheduled bank, shall maintain cash reserve with itself or by way of balance in a current account with the RBI. Such cash reserve shall be equivalent to at least

COMMISSIONER OF INCOME TAX-II, HYDERABAD vs. M/s. The A.P.Vardhaman(Mahila)Cooperative Urban

In the result, for the above reasons, these appeals fail and

ITTA/715/2006HC Telangana07 Jun 2011

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

Section 260ASection 46Section 80P(2)(a)

transfer to the reserve fund a sum equivalent not less than 20% of such profit. Further, under Section 18 of the BR Act, every banking company, not being a scheduled bank, shall maintain cash reserve with itself or by way of balance in a current account with the RBI. Such cash reserve shall be equivalent to at least

Commissioner of Income Tax-II, vs. M/S The A.P.Mahesh Coop. Urban Bank Ltd,

In the result, for the above reasons, these appeals fail and

ITTA/718/2006HC Telangana07 Jun 2011

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

Section 260ASection 46Section 80P(2)(a)

transfer to the reserve fund a sum equivalent not less than 20% of such profit. Further, under Section 18 of the BR Act, every banking company, not being a scheduled bank, shall maintain cash reserve with itself or by way of balance in a current account with the RBI. Such cash reserve shall be equivalent to at least

Commissioner of Income Tax -II vs. The Agrasen Coop. Urban Bank Ltd.,

In the result, for the above reasons, these appeals fail and

ITTA/711/2006HC Telangana07 Jun 2011

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

Section 260ASection 46Section 80P(2)(a)

transfer to the reserve fund a sum equivalent not less than 20% of such profit. Further, under Section 18 of the BR Act, every banking company, not being a scheduled bank, shall maintain cash reserve with itself or by way of balance in a current account with the RBI. Such cash reserve shall be equivalent to at least

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

63. From the reading of the above judgments it is clear that a Development Agreement is to be distinguished from a pure construction contract. In a pure construction contract, the contractor has no interest in either the land or the construction which is carried out. The Supreme Court in Sushil Kumar Agarwal (supra) has given instances of Development Agreement where

Commissioner of Income Tax, vs. Agriculturel Market Committee,

In the result, the appeal fails and is hereby dismissed

ITTA/219/2011HC Telangana27 Jun 2011

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

Section 260Section 263

63 YEARS S/O SRI. HANUMAN PRASAD DHANUKA. ... APPELLANT (BY SMT.JINITHA CHATTERJEE, LEARNED COUNSEL FOR SRI. S. PARTHASARATHI, ADV.) AND: THE ASST. COMMISSIONER OF INCOME TAX CIRCLE-11(4), BANGALORE-560001. ... RESPONDENT (BY SRI. K.V. ARAVIND, ADV.) - - - 2 THIS I.T.A. IS FILED UNDER SECTION 260-A OF I.T.ACT, 1961 ARISING OUT OF ORDER DATED 07.03.2011 PASSED IN ITA NOs.403 & 404/BANG/2011