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30 results for “transfer pricing”+ Section 75clear

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Key Topics

Addition to Income13Section 26010Section 968Section 1517Section 260A5Section 9(1)(vi)5Section 13(1)(e)4Section 214Section 143(3)

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 proceedings, the TPO had selected M/s. HMT Limited as one of the comparables on functional similarity, but while determining the ALP, he had not included M/s. HMT limited as a comparable. The learned Tribunal held: “7.3 We heard the rival submissions and perused the material placed on record. M/s. HMT Ltd., is in the segment of manufacturing

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)

Showing 1–20 of 30 · Page 1 of 2

3
Double Taxation/DTAA3
Survey u/s 133A3
Capital Gains2
Section 45(1)
Section 48
Section 54F

price of each share of NIIT as Rs.1,493/-, instead of Rs.500/- per share. 11. Appeals filed by the assessee were dismissed by the Commissioner of Income Tax (Appeals) vide orders dated 13th March, 2002. 12. Tribunal by common order dated 29th January, 2004 has dismissed the second appeals filed by the assessee. Tribunal in the impugned order has referred

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

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

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

75,000/­.   Same   loss   of   Rs.   82,000/­is  therefore directed to be allowed in the sale of  shares of Mysore Cement. As regards UTI master and  L & T shares, no rate adjustment is called for and  loss   as   claimed   of   Rs.   15,31,250/­   is   to   be  allowed   in   full.   Thus,   total   short   term   capital  loss

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

ITTA/211/2008HC Telangana23 Mar 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

75,000/­.   Same   loss   of   Rs.   82,000/­is  therefore directed to be allowed in the sale of  shares of Mysore Cement. As regards UTI master and  L & T shares, no rate adjustment is called for and  loss   as   claimed   of   Rs.   15,31,250/­   is   to   be  allowed   in   full.   Thus,   total   short   term   capital  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

75,000/­.   Same   loss   of   Rs.   82,000/­is  therefore directed to be allowed in the sale of  shares of Mysore Cement. As regards UTI master and  L & T shares, no rate adjustment is called for and  loss   as   claimed   of   Rs.   15,31,250/­   is   to   be  allowed   in   full.   Thus,   total   short   term   capital  loss

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

75 against the subsequent WP-211-2006 -14- purchasers and the original landlord Dadarao for a decree of perpetual injunction. Learned Civil Judge Senior Division, Osmanabad had referred the tenancy issue to the tenancy court and accordingly, deceased Deorao Bajirao Thorat had initiated proceedings before the Naib Tahsildar bearing case no. 96/TNC/80/38. Initially, learned Naib Tahsildar was pleased to hold

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 paid for the land in question. Therefore, there is no scope for plea of poverty. It has come in the evidence of DW.1 that this defendant was informed of plaintiff’s transaction. As a businessman, he ought to have made reasonable enquiry, obviously that would include about the court proceedings. What enquiries were made

Commissioner of Income Tax, vs. M/s Y.Ramakrishna and others

ITTA/172/2003HC Telangana21 Jun 2011

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

Section 1Section 151Section 96

75,OOO/- on 23.02.7999 and (iii) Rs. 3,81,750/ on23.O4.1999. It Is the case of vendors that purchaser did not pay balance sale consideration of Rs. 11,3I,75O1-. The purchaser did not dispute the default on his part in payment of balance sale consideration, however, \\ -..,,- t2 he tried to justify his default by pleading that vendors failed

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

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 - 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

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

Commissioner of Income Tax vs. Agrilcultural Market Committee

ITTA/148/2011HC Telangana20 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

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

Section 110 of the Act, if an AOP is chargeable to tax at maximum marginal rate then the share of profits in the hands of the members is not chargeable to tax at all. 19. Now against the above contours of taxability of an AOP, we have to see the facts of the case before us. The first

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 Pr. Commissioner of Income Tax [Central] vs. M/s Nallamala Agro Farms Pvt Ltd.,

ITTA/170/2017HC Telangana20 Apr 2017

Bench: J. UMA DEVI,V RAMASUBRAMANIAN

Section 260Section 92

Transfer Pricing Officer to exclude M/s. Persistent Systems Ltd., as its RPT is 15.47 and to include Thinksoft Global Services Ltd., even without proper application of principles for adopting the same? 4. Whether on the facts and in the circumstances of the case, the Tribunal was right Date of Judgment 18-07-2018, ITA No.170/2017 Pr. Commissioner of Income

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, 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. 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

75. In Vinod Seth (Supra), specific performance was being sought of an oral Agreement which also provided for transfer of ground floor of a building to be constructed in favour of the builder upon such construction. The Supreme Court refused to grant such relief to the plaintiff therein and held as under:- CS(OS) No.486/2011 Page 41 “13. The agreement