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Search Results for "income tax transfer"

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High Court

High Court of Karnataka Hears Revenue's Appeal Against Income Tax Appellate Tribunal Order Deleting Transfer Pricing and Bogus Expense Additions for Assessment Year 2009-10. The Appeal Involves Interpretation of Associated Enterprise Under Section 92A and Right of Cross-Examination When Additions Are Based on Third-Party Statements.

17 Mar 2023

The Revenue filed an appeal under Section 260A of the Income Tax Act, 1961 before the High Court of Karnataka, Dharwad Bench, challenging the order da...

High Court

Bombay High Court Allows Writ Petition Challenging Rejection of Application Under Section 197 of Income Tax Act for Lower Tax Deduction on Dividend Income. The court held that a Tax Residency Certificate (TRC) is sufficient evidence of residence for claiming treaty benefits under the India-Mauritius DTAA, and the Assessing Officer must consider the DTAA provisions.

26 Apr 2019

The petitioner, Indostar Capital, a Mauritius-based company incorporated in October 2010, held a Category 1 Global Business Licence and a Tax Residenc...

High Court

Bombay High Court Upholds Tribunal's Restriction on Section 80HHB Deduction and Denial of Deduction for Foreign Tax Paid. The court held that only amounts transferred to Foreign Project Reserve Account during the previous year qualify for deduction under Section 80HHB, and tax paid abroad is not deductible under the Income Tax Act.

20 Dec 2016

The case involves an income tax reference by the Income Tax Appellate Tribunal to the Bombay High Court under Section 256(1) of the Income Tax Act, 19...

High Court

Bombay High Court Allows Assessee's Appeal in Income Tax Case Regarding Deduction of Mortgage Repayment Under Section 48(i). The court held that repayment of mortgage debt is an expenditure incurred in connection with transfer of mortgaged asset, allowable under Section 48(i) of Income Tax Act, 1961.

31 Jan 2005

The judgment involves two tax appeals, one by the revenue and one by the assessee, arising from a common issue regarding the allowability of mortgage ...

High Court

Bombay High Court Allows Revenue's Appeal in Part and Assessee's Appeal on Mortgage Repayment Issue. Repayment of mortgage debt created by the assessee is an expenditure incurred in connection with the transfer of mortgaged asset allowable under Section 48(i) of the Income Tax Act, 1961.

31 Jan 2005

The judgment involves two tax appeals, one by the revenue and one by the assessee, arising from a common issue regarding the allowability of repayment...

High Court

High Court of Karnataka Dismisses Revenue's Appeal in Transfer Pricing Case for Acer India Pvt. Ltd. — No Substantial Question of Law Arises. Tribunal's deletion of TP adjustment upheld as consistent with earlier assessment year order.

25 Jun 2018

The Revenue filed an appeal under Section 260-A of the Income Tax Act, 1961 against the order of the Income Tax Appellate Tribunal (ITAT) dated 29.11....

High Court

Madras High Court Dismisses Revenue's Appeal in Lottery Ticket Commission TDS Case — Difference Between Face Value and Sale Price Not 'Commission' Under Section 194G of Income Tax Act, 1961. The court held that trade discount given to agents/dealers for encouraging sale of lottery tickets does not amount to commission requiring tax deduction at source, and thus no liability under Sections 201(1) and 201(1A) arises.

9 Apr 2026

The case involves a tax dispute between the Commissioner of Income Tax, Coimbatore (petitioner) and M/s Martin Lottery Agencies Ltd (respondent/assess...

High Court

High Court of Bombay Examines Jurisdictional Challenge to Transfer Pricing Adjustment on Equity Share Issuance. Whether Alleged Shortfall in Premium Constitutes Income from International Transaction Under Chapter X of Income Tax Act, 1961.

10 Oct 2014

Vodafone India Services Pvt. Ltd. (the Petitioner), a wholly owned subsidiary of a non-resident holding company, required funds for its telecommunicat...

High Court

Bombay High Court Allows Writ Petition Challenging Transfer Pricing Reference and Order for Lack of Proper Approval Under Section 92D of Income-tax Act, 1961. The court held that the reference made by the Assessing Officer to the Transfer Pricing Officer without obtaining the requisite approval was invalid, and the subsequent order of the TPO was also invalid.

23 Dec 2011

The petitioner, M/s. Hindalco Industries Ltd., filed a writ petition under Article 226 of the Constitution challenging (i) an order dated 31 October 2...

High Court

Bombay High Court Allows Assessee's Appeal on Proportional Increase of Advertisement Limit and Deductibility of Statutory Fund Transfer. Holds that Section 37(3A) limit must be proportionately increased for extended previous year and transfer to statutory storage fund is deductible under Section 37(1).

30 Sep 2016

This judgment by the Bombay High Court addresses four questions of law referred by the Income Tax Appellate Tribunal under Section 256(1) of the Incom...

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