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

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

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-II vs. The Andhra Bank Employees Co.Operative Bank Limited

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

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

9] holding that, “the expression ‘attributable to’ is certainly wider in import than the expression ‘derived from’.” It was also held that by using the expression ‘attributable to’, the legislature intended to cover receipts from sources other than the actual conduct of business. Section 80P of the Act grants deduction in respect of various categories of income of a cooperative

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

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

9] holding that, “the expression ‘attributable to’ is certainly wider in import than the expression ‘derived from’.” It was also held that by using the expression ‘attributable to’, the legislature intended to cover receipts from sources other than the actual conduct of business. Section 80P of the Act grants deduction in respect of various categories of income of a cooperative

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

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

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

9] holding that, “the expression ‘attributable to’ is certainly wider in import than the expression ‘derived from’.” It was also held that by using the expression ‘attributable to’, the legislature intended to cover receipts from sources other than the actual conduct of business. Section 80P of the Act grants deduction in respect of various categories of income of a cooperative

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

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

9] holding that, “the expression ‘attributable to’ is certainly wider in import than the expression ‘derived from’.” It was also held that by using the expression ‘attributable to’, the legislature intended to cover receipts from sources other than the actual conduct of business. Section 80P of the Act grants deduction in respect of various categories of income of a cooperative

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

Appeals are disposed of, with no order as to costs

Bench: C.V. BHASKAR REDDY,UJJAL BHUYAN

9. Upon exhaustive and detailed examination, the Assessing Officer concluded that non-cumulative preference shares were not allotted and was a sham and a cover up to show that the transfer was on 14th August, 1997 to justify sale price of Rs.450/-, when the fair market value of each share of NIIT prevailing on the date of transfer, i.e. 30th

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

In the result, the appeal fails and is hereby dismissed

Bench: RAMESH RANGANATHAN,KONGARA VIJAYA LAKSHMI

Transfer Pricing Officer has gone into the provision of Section 92A(2) of the Act. It is further submitted that the provisions of sub- Sections (1) and (2) of Section 92A are interlinked and have been read together harmoniously and therefore, the substantial question of law framed in this appeal is required to be answered in favour of the assessee

The Commissioner of Income Tax-IV vs. M/s Pokarna Limited

The appeals are dismissed

Bench: P.SAM KOSHY,NARSING RAO NANDIKONDA

Section 80IA(8) requiring adoption of market value of goods in place of the actual - - 15 sale price in the cases of certain specified sales, and the transfer pricing rules, it held the Assessing Authority does not have the power to substitute the value for the actual sale price in the absence of any evidence of understatement of the value

Principal Commissioner of Income Tax-3 vs. M/s Satyasai Bhavani Hsopitals Private Limited

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

2) An appeal may lie under this section from an appellate decree passed ex- parte. Date of Judgment 25-06-2018 I.T.A.No.536/2015 C/w I.T.A.No.537/2015 Pr. Commissioner of Income Tax & Anr. Vs. M/s. Softbrands India P. Ltd., 35/80 (3) In an appeal under this section, the memorandum of appeal shall precisely state the substantial question of law involved

The Commissioner of Income Tax-II, vs. M/S Gulf Oil Corporation Pvt. Ltd.,

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

2,01,250 19.2.92 40.25 9,80,000 16.1.92 Rs.4,43,750/­ c) 30,000 12,22,500 19.2.92 40.75 28 L & T 19,45,000 18.2.92 a) 10,000 194.50 21,30,000 b) 5,000 9,35,000 19.2.92 187.00 21.1.92 142.00 Rs.7,50,000/­ Total LossRs.16,88,250/­ 8.2. The   Assessing   Officer   after   verification  found that

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

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

2,01,250 19.2.92 40.25 9,80,000 16.1.92 Rs.4,43,750/­ c) 30,000 12,22,500 19.2.92 40.75 28 L & T 19,45,000 18.2.92 a) 10,000 194.50 21,30,000 b) 5,000 9,35,000 19.2.92 187.00 21.1.92 142.00 Rs.7,50,000/­ Total LossRs.16,88,250/­ 8.2. The   Assessing   Officer   after   verification  found that

The Commissioner of Income Tax - VI vs. M/s. Manikanta Iron AND Hardware

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

2,01,250 19.2.92 40.25 9,80,000 16.1.92 Rs.4,43,750/­ c) 30,000 12,22,500 19.2.92 40.75 28 L & T 19,45,000 18.2.92 a) 10,000 194.50 21,30,000 b) 5,000 9,35,000 19.2.92 187.00 21.1.92 142.00 Rs.7,50,000/­ Total LossRs.16,88,250/­ 8.2. The   Assessing   Officer   after   verification  found that

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

Accordingly, the learned appellate authority has rightly dismissed the

Bench: P.SAM KOSHY,LAXMI NARAYANA ALISHETTY

9. … We fail to understand how a valid grievance can be made in respect of such deduction when the very extension of the benefit of set-off is itself a boon or a concession. It was open to the rule-making authority to provide for a small abridgement or curtailment while extending a concession. Viewed from this angle, the argument

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

Accordingly, the learned appellate authority has rightly dismissed the

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

9. … We fail to understand how a valid grievance can be made in respect of such deduction when the very extension of the benefit of set-off is itself a boon or a concession. It was open to the rule-making authority to provide for a small abridgement or curtailment while extending a concession. Viewed from this angle, the argument

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

In the result, the orders passed by the Assessing

Bench: SANJAY KUMAR,GUDISEVA SHYAM PRASAD

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

Bench: SANJAY KUMAR,GUDISEVA SHYAM PRASAD

9, 21 to 24.  Union of India Vs. Paliwal Electricals Pvt. Ltd, reported in (1996) 3 SCC 407, para- 8 to 10. 20. The learned Advocate General while placing reliance upon Section-94 of the JVAT Act, 2005, more particularly the provisions contained under sub-Section 3 of Section-94 has contended that a bare 42 reading of the said

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

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

9, 21 to 24.  Union of India Vs. Paliwal Electricals Pvt. Ltd, reported in (1996) 3 SCC 407, para- 8 to 10. 20. The learned Advocate General while placing reliance upon Section-94 of the JVAT Act, 2005, more particularly the provisions contained under sub-Section 3 of Section-94 has contended that a bare 42 reading of the said

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

2) The entire contract would not be attributable to the operations in India viz. the place of execution of the contract, assuming the offshore elements form an integral part of the contract. (3) Section 9(1)(vii) of the Act read with Memo cannot be given a wide meaning so as to hold that the amendment was only to include