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26 results for “transfer pricing”+ Section 90(2)clear

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Key Topics

Addition to Income10Section 9(1)(vi)5Section 964Section 1514Section 260A3Section 143(3)3Section 2603Section 13(1)(a)3Section 108

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

90% of the total refund claimed was allowed to the tune of 6,70,26,012/- and show cause notice ₹ was issued to the petitioner on 7-6-2019 vide Annexure P-5 as to why the refund claimed to the extent of 51,48,531/- should not ₹ be rejected to which the petitioner filed its reply

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

Showing 1–20 of 26 · Page 1 of 2

3
Double Taxation/DTAA2

90% of the total refund claimed was allowed to the tune of 6,70,26,012/- and show cause notice ₹ was issued to the petitioner on 7-6-2019 vide Annexure P-5 as to why the refund claimed to the extent of 51,48,531/- should not ₹ be rejected to which the petitioner filed its reply

M/s. Canara Securities Ltd vs. Dy. Commissioner of Income Tax

ITTA/3/2020HC Telangana25 Aug 2020

Bench: M.S.RAMACHANDRA RAO,T.AMARNATH GOUD

90, 91, 92, 94, 95, 96 AND 98 OF 2020) REPORTABLE Page 83 of 300 APLs to act by majority is contrary to law and to the order of appointment of the APLs. 23. It is submitted that the decision of two of the APLs to re-investigate into the extent of the estate and percentage of share holding

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

2. 2009 (7) SCC 363 - Suraj Lamp and Industries Private Limited. -Vs- State of Haryana & Another 3. 2010 (8) SCC 383 - Meghamala and Ors.-Vs-G Narasimha Reddy and Ors. 4. 2011(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

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

ITTA/249/2013HC Telangana11 Jul 2013
Section 4

90 STC 1 (SC) 45. (1976) 4 SCC 460 46. AIR 1996 SC 1854 47. (2014) 3 SCC 732 48. 1935 (37) BomLR 866 49. AIR 1997 SC 2502 50. (1963) Suppl. 2 S.C.R. 608 51. (1998) 111 STC 657; 52. (1999) U.P.T.C. 13; 53. (1998) STC 111 467; 54. 2008 (230) E.L.T. 385 (S.C.) Coram: Hon’ble Ramesh Ranganathan

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.CHENNAKESAVA VIJAYAWADA vs. THE COMMISSIONER OF INCOME TAX VIJAYAWAD

The Appeal is dismissed

ITTA/33/2000HC Telangana27 Aug 2012

Bench: GODA RAGHURAM,M.S.RAMACHANDRA RAO

Section 194CSection 197(1)Section 201

90,752/=, the TDS deductible @ 2% was Rs. 1,84,41,814/=. The appellant-Company, while submitting a letter dated 18th May 1998 providing the details of payments made to Messrs. Essar Projects Limited, made a mention of payment made towards procurement of material to the tune of Rs. 72.60 Crores. The I.T.O with regard to the supply of these

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-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

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

90 of 2013 “Ramesh S/o Vithal Mane and others Vs. Gurling S/o Mahadeo Bhavare and others”, wherein it has been observed thus, “16. The above said circumstances show that, before the learned Single Judge of this Court, the decision of MRT was challenged and the decision was given within scope of provisions of Section 91 of the Hyderabad Tenancy

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 (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

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

The Pr. Commissioner of Income-tax vs. D.L.V. Sridhar

ITTA/365/2018HC Telangana22 Oct 2018

Bench: D.V.S.S.SOMAYAJULU,RAMESH RANGANATHAN

Section 10Section 10ASection 115Section 260

2 of 9 non-STPI zone and hence its income was taxable. The other unit was located in a STPI zone in Gurgaon and its income was exempted under Section 10-A of the Act. The STPI unit was engaged in the business of development and support of its parent company in US/sister concerns worldwide as well as their customers

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 Pr. Commissioner of Income tax (Central), vs. Sri Vaishnavi Educational Society,

ITTA/622/2015HC Telangana01 Jun 2016

Bench: The Hon’Ble Mr. Justice Aravind Kumar W.P. No.51929/2014 C/W W.P.Nos.42063/2012, 30494/2013, 42671/2013, 638/2014, 797/2014, 1089/2014, 3211/2014, 3389/2014, 6180/2014, 10356/2014, 12014/2014, 12015/2014, 13043/2014, 13045/2014, 13206/2014, 13207/2014, 13398/2014, 13774/2014, 14149/2014, 14161/2014, 14494/2014, 14502/2014, 14521/2014, 14689/2014, 16646/2014, 17051/2014, 17594/2014, 19729/2014, 21158/2014, 23897/2014, 28861/2014, 30731/2014, 31723/2014, 33774/2014, 33777/2014, 34084/2014, 34259/2014, 34272/2014, 34391/2014, 35204/2014, 35243/2014, 35247/2014, 35305/2014, 35609/2014, 36164/2014, 36166/2014, 36489/2014, 36525/2014, 36971/2014, 37446/2014, 38055/2014, 38463/2014, 38471/2014, 38472/2014, 38661/2014, 38753/2014, 39383/2014, 39633/2014, 39832/2014, 40204/2014, 40379/2014, 41394/2014, 41422/2014, 41427/2014, 41428/2014, 41858/2014, 43815/2014, 43963/2014, 44306/2014, 44527/2014, 44742/2014, 44835/2014, 45486/2014, 46766/2014, 47103/2014, 47105/2014, 47106/2014, 47107/2014, 47608/2014, 47731/2014, 47821/2014, 47860/2014, 47913/2014, 48577/2014, 48880/2014, 49567/2014, 50260/2014, 50533/2014, 51294/2014, 51930/2014, 51931/2014, 51932/2014, 52760/2014, 53854/2014, 54059/2014, 54083/2014, 54236/2014

2. BANGALORE DEVELOPMENT AUTHORITY REP BY ITS COMMISSIONER KUMARA PARK WEST BANGALORE-560020 3. SPECIAL LAND ACQUISITION OFFICER BANGALORE DEVELOPMENT AUTHORITY KUMARA PARK WEST BANGALORE-560020 …RESPONDENTS (BY SRI. G.V. SHASHIKUMAR, AGA FOR R1; SRI. M.N. RAMANJANEYA GOWDA, ADVOCATE FOR R2; SRI. D.N. NANJUNDA REDDY, SR. COUNSEL FOR SRI. B.S. SACHIN, ADVOCATE FOR R3) THIS W.P. IS FILED UNDER ARTICLE

Khorshed Shapoor Chenai vs. Asst.Commissioner of Income Tax,

Appeal stands disposed of setting aside the impugned

ITTA/47/2009HC Telangana27 Mar 2025

Bench: P.SAM KOSHY,NARSING RAO NANDIKONDA

90% of the sale price. It was pleaded that the bank was ready and willing to pay the balance consideration. 16. Upon being served with the summons for settlement of issues, the appellant raised, by way of preliminary objection No.1, the defence that the agreement Ex.P-1 was a loan transaction; camouflaged in the language as desired by the officers

THE COMMISSIONER OF INCOME TAX III, vs. M/S. SAVIJANA SEA FOODS PVT. LTD.,

Appeals of the Revenue are dismissed

ITTA/55/2010HC Telangana20 Dec 2024

Bench: J SREENIVAS RAO,ALOK ARADHE

Section 260

price of the jewellery stolen in a robbery or a burglary was therefore expenditure for the purpose of the business. There can be no doubt that the expenditure was wholly and exclusively in the interest of the business. The expenditure was laid out for no other purpose.” 33. Applying the law explained by the Supreme Court in the above decisions

Commissioner of Income Tax, vs. M/s. Kokivenkateswara Reddy AND others,

Appeals of the Revenue are dismissed

ITTA/210/2003HC Telangana21 Jun 2011

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

Section 260

price of the jewellery stolen in a robbery or a burglary was therefore expenditure for the purpose of the business. There can be no doubt that the expenditure was wholly and exclusively in the interest of the business. The expenditure was laid out for no other purpose.” 33. Applying the law explained by the Supreme Court in the above decisions