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6 results for “reassessment u/s 147”+ TP Methodclear

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Delhi42Bangalore21Mumbai20Chennai18Kolkata11Hyderabad8Ahmedabad6Indore5Jaipur5Visakhapatnam2Karnataka1Chandigarh1Pune1

Key Topics

Section 2636Section 143(3)6Transfer Pricing5Disallowance5Addition to Income5Section 14Depreciation4Section 1472

SHAMA AJAY PATEL,AHMEDABAD vs. THE CIT(IT & TP), AHMEDABAD

The appeal of the assessee is allowed

ITA 132/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad26 Apr 2024AY 2017-18

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarिनधा"रण वष"/Assessment Year: 2017-18 Shama Ajay Patel, Vs. 2, Chandroday Society, The Cit(It & Tp), Opp. Golden Triangle, Sp Ahmedabad Stadium Road, Navjivan Post, Ahmedabad-380014 Pan : Alxpp 5273 E अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" "" यथ" "" "" यथ" यथ"/ (Respondent) यथ" Assessee By : Shri Sunil Talati, Ar Revenue By : Dr. Darsi Suman Ratnam, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 01.02.2024 घोषणा क" तारीख /Date Of Pronouncement: 26.04.2024 आदेश आदेश/O R D E R आदेश आदेश Per Annapurna Gupta: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Learned Commissioner Of Income-Tax (It & Tp), Ahmedabad [Hereinafter Referred To As Ld. "Cit(It & Tp)" For Short] Dated 08.02.2023, In Exercise Of His Revisionary Powers Under Section 263 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”], For The Assessment Year (Ay) 2017-18. 2. The Grounds Raised By The Assessee Challenging The Impugned Order Of The Ld. Cit (It & Tp) Reads As Under:- “1. The Ld. Cit Has Erred In Passing Order U/S 263 Without Jurisdiction & Appropriate Powers Available Under The Act. It Is Submitted That The Order Passed U/S. 263 Is Bad In Law As A.O. Has Neither Committed Any Error Nor It Is Prejudicial To The Interest Of Revenue. It Be Held Now.

For Appellant: Shri Sunil Talati, ARFor Respondent: Dr. Darsi Suman Ratnam, CIT-DR
Section 132Section 147Section 263

reassessment proceedings u/s 147 of the Act. The assessee had filed original return of income for the impugned year declaring total income of Rs.72,33,120/-. Subsequently, based on information available on record, the case of the assessee was reopened u/s 147 of the Act and thereafter assessment was finalized accepting the returned income. The ld. CIT (IT & TP

DCIT, CIRCLE-1(1)(1),, AHMEDABAD vs. ADANI ENTERPRISES LTD., AHMEDABAD

In the result appeal of the Revenue is hereby partly allowed

ITA 285/AHD/2020[2013-14]Status: DisposedITAT Ahmedabad17 Aug 2022AY 2013-14

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

For Respondent: Shri Vartik Choksi, A.R
Section 1Section 143(3)

reassess undersection 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee undersection 154, for any assessment year beginning on or before the 1st day of April, 2001." 47.2 As per the provisions of sub-section (1) of Section14A of the Act, the AO is empowered

DCIT, CIRCLE-1(1)(1),, AHMEDABAD vs. ADANI ENTERPRISES LTD., AHMEDABAD

In the result appeal of the Revenue is hereby partly allowed

ITA 336/AHD/2020[2014-15]Status: DisposedITAT Ahmedabad17 Aug 2022AY 2014-15

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

For Respondent: Shri Vartik Choksi, A.R
Section 1Section 143(3)

reassess undersection 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee undersection 154, for any assessment year beginning on or before the 1st day of April, 2001." 47.2 As per the provisions of sub-section (1) of Section14A of the Act, the AO is empowered

THE DCIT CIRCLE-1(1)(1), AHMEDABAD vs. M/S. ADANI ENTERPRISE LTD, AHMEDABAD

In the result appeal of the Revenue is hereby partly allowed

ITA 472/AHD/2020[2015-16]Status: DisposedITAT Ahmedabad17 Aug 2022AY 2015-16

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

For Respondent: Shri Vartik Choksi, A.R
Section 1Section 143(3)

reassess undersection 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee undersection 154, for any assessment year beginning on or before the 1st day of April, 2001." 47.2 As per the provisions of sub-section (1) of Section14A of the Act, the AO is empowered

THE DCIT, CIRCLE-1(1)(1), AHMEDABAD vs. M/S. ADANI ENTERPRISE LTD, AHMEDABAD

In the result appeal of the Revenue is hereby partly allowed

ITA 523/AHD/2020[2016-17]Status: DisposedITAT Ahmedabad17 Aug 2022AY 2016-17

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

For Respondent: Shri Vartik Choksi, A.R
Section 1Section 143(3)

reassess undersection 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee undersection 154, for any assessment year beginning on or before the 1st day of April, 2001." 47.2 As per the provisions of sub-section (1) of Section14A of the Act, the AO is empowered

SUN PHARMACEUTICALS INDUSTRIES LTD. ( ERSTWHILE RANBAXY LABORATORIES LIMITED),BARODA vs. THE ACIT,CENT.CIRCLE-1, BARODA

ITA 702/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad08 Apr 2021AY 2011-12
For Appellant: Shri S.N. Soparkar, Sr. A.RFor Respondent: Shri Mohd Usman, CIT-D.R
Section 115JSection 143(2)Section 143(3)Section 144CSection 144C(5)Section 37(1)Section 92C

TP provisions of other countries and reading it into our provisions is not permissible. The requirement under our law is to compute the income from an international transaction between two AEs having regard to its ALP and the same is required to be strictly adhered to as prescribed. This contention is, therefore, repelled." With have duly perused the findings