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38 results for “transfer pricing”+ Section 9(1)(vi)clear

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Key Topics

Section 260A15Section 10(20)10Addition to Income9Section 80P(2)(a)8Section 46Section 12A6Exemption6Section 965Section 2605

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)

transfer of all or any rights (including the granting of a licence) in respect of any copyright, literary, artistic or scientific work including films or video tapes for use in connection with ITA 473/2012, 474/2012, 500/2012 & 244/2014 Page 8 television or tapes for use in connection with radio broadcasting, but not including consideration for the sale, distribution or exhibition

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

ITTA/322/2008HC Telangana04 Apr 2016

RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Showing 1–20 of 38 · Page 1 of 2

Section 9(1)(vi)5
Business Income5
Deduction4
Bench:
Section 108Section 13(1)(a)Section 13(1)(b)Section 13(1)(e)

9 of that report, the Apex Court referred to Section 105 of the T.P.Act. Section 105 defines lease. It lays down that a lease of immovable property is a transfer of a right to enjoy such property, made for a certain time, express or implied, or in perpetuity, in consideration of a price paid or promised, or of money

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

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

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

ITTA/455/2017HC Telangana06 Jul 2017

Bench: SANJAY KUMAR,GUDISEVA SHYAM PRASAD

VI, Industrial Area, Gamharia, Jamshedpur through its Director, Sudhir Rai ..... … Petitioner 25 Versus 1. The State of Jharkhand, through the Secretary, Finance Department, Project Building, Dhurwa, Ranchi 2. The Commissioner of Commercial Taxes, Project Bhawan, Dhurwa, Ranchi 3. Joint Commissioner of Commercial Taxes (Administration), Jamshedpur, Division, Jamshedpur. 4. Deputy Commissioner of Commercial Taxes, (Adityapur Circle), Jamshedpur 5. Assistant Commissioner

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

ITTA/134/2016HC Telangana14 Jul 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

VI, Industrial Area, Gamharia, Jamshedpur through its Director, Sudhir Rai ..... … Petitioner 25 Versus 1. The State of Jharkhand, through the Secretary, Finance Department, Project Building, Dhurwa, Ranchi 2. The Commissioner of Commercial Taxes, Project Bhawan, Dhurwa, Ranchi 3. Joint Commissioner of Commercial Taxes (Administration), Jamshedpur, Division, Jamshedpur. 4. Deputy Commissioner of Commercial Taxes, (Adityapur Circle), Jamshedpur 5. Assistant Commissioner

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

vi) of the Act?” 2. Insofar as questions „B‟ and „C‟ are concerned, it could not be disputed before us that those also formed the subject matter of ITA 475/2009 and the decision on which came to be followed in ITA 751/2010. While dealing with those questions, the Court while dismissing ITA 475/2009 had observed as follows: - “Learned counsel

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

9 (4-16), 12 (4-16), 13/1 (0-11) and 27(0-4). CS(OS) No. 78/2007 Page 2 of 43 2. The case of the plaintiff is that the four defendants had equal 1/4th co-ownership rights in the suit land and which suit land was agreed to be sold for a total price of Rs.5

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

Commissioner of Income-Tax, vs. Rangaraya Medical College Old Students Association

ITTA/269/2005HC Telangana14 Mar 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

For Appellant: SRI CHALLA GUNARANJAN
Section 1Section 151

Vi;-Chil;6r;,di, Guntur Dist. rep by its Managing Director Mr' N Ragahava Rao ...APPELLANT/PET'r'.NER 4 AND l.A. 1. Transmission Corporation of A.P. Ltd., Vidyut Soudha, Khairatabad, Hyderabad. rep by Chairman and Managing Director 2. Southem Power Distribution Company A.P.Ltd., 19-3-1 3, Upstairs of Hero Honda Show Room, Renigunta Road, Tirupathi

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

ITTA/249/2013HC Telangana11 Jul 2013
Section 4

vi) the validity of the recognition certificate must have commenced prior to November 9, 2000 (when the State of Uttarakhand came into being), for the use in (a) the manufacture of goods, and (b) in the packing of goods manufactured by him; (vii) on fulfillment of these conditions, tax shall be calculated at such rates as would have been leviable

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

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

vi) The 12th respondent will be permitted to operate the WP(C). 11249/2010 & other contd cases. -:78:- quarry in question in strict compliance with the conditions in Ext.P3 till 31-12- 2020 if, the Government of Kerala permits mining activity upon the land in the decision to be taken in furtherance of the directions issued by this Court

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

VI. Duty of Division Bench in LPA to decide on facts if Single Judge's order in substance falls under Art. 226, wholly or partially - Division Bench to which LPA is made, is required to ascertain whether facts justify assertions made in writ petition to invoke jurisdiction under Art. 227 or 30 LPA-22-2008+ Art. 226 or under both/whether

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

vi) As per clause (9) the vendors declare that the purchaser can enjoy the schedule mentioned property as sole and absolute owner $'ithout any disturbance, Iet or hindrance either from the Vendors or from anybody else claiming through or under the vendors. (vii) As per clause (11) in the event of the entire sale consideration as agreed is paid inspite

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-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

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 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

9) SCC 1 - K.T.Plantation Private Limited & Anr. Vs. State of Karnataka”. 95. As discussed above, with reference to Section 54 of the Transfer of Property Act, the sale of immoveable property worth 100 or more than 100 is to be effected through registered document which invariably supposes that it shall be in writing and 90 sufficient non judicial stamp shall

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