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31 results for “transfer pricing”+ Section 192clear

Sorted by relevance

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Key Topics

Section 14A46Section 143(3)35Section 8027Deduction22Disallowance16Depreciation14Addition to Income14Section 43B10Section 409

THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1) (1),, AHMEDABAD vs. M/S. INTAS PHARMACEUTICALS PVT. LTD.,, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

ITA 1646/AHD/2017[2011-12]Status: DisposedITAT Ahmedabad31 Jan 2024AY 2011-12

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. AdvocateFor Respondent: Dr. Darsi Suman Ratnam, CI

192,52 0.19 0.19 0.09 expenditure R&O revenue 5409.10 370742 1101,3.8 1492,86 746.42 208.42 104.21 expenditure Total 5,601.81 3900.34 1701.47 746.43 208.61 104.305 4. Without prejudice to Ground No. 3 above, in the facts and circumstances of the case, the learned C1T(A) further erred in stating amount of disallowance towards weighted portion of disallowance under

INTAS PHARMACEUTICALS LTD.,,AHMEDABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

ITA 1335/AHD/2017[2010-11]Status: DisposedITAT Ahmedabad

Showing 1–20 of 31 · Page 1 of 2

Section 40A(3)9
Section 40A(7)9
Comparables/TP6
31 Jan 2024
AY 2010-11

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. AdvocateFor Respondent: Dr. Darsi Suman Ratnam, CI

192,52 0.19 0.19 0.09 expenditure R&O revenue 5409.10 370742 1101,3.8 1492,86 746.42 208.42 104.21 expenditure Total 5,601.81 3900.34 1701.47 746.43 208.61 104.305 4. Without prejudice to Ground No. 3 above, in the facts and circumstances of the case, the learned C1T(A) further erred in stating amount of disallowance towards weighted portion of disallowance under

INTAS PHARMACEUTICALS LTD.,,AHMEDABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

ITA 1334/AHD/2017[2009-10]Status: DisposedITAT Ahmedabad31 Jan 2024AY 2009-10

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. AdvocateFor Respondent: Dr. Darsi Suman Ratnam, CI

192,52 0.19 0.19 0.09 expenditure R&O revenue 5409.10 370742 1101,3.8 1492,86 746.42 208.42 104.21 expenditure Total 5,601.81 3900.34 1701.47 746.43 208.61 104.305 4. Without prejudice to Ground No. 3 above, in the facts and circumstances of the case, the learned C1T(A) further erred in stating amount of disallowance towards weighted portion of disallowance under

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD vs. INTAS PHARMACEUTICALS PVT. LTD.,, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

ITA 1644/AHD/2017[2009-10]Status: DisposedITAT Ahmedabad31 Jan 2024AY 2009-10

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. AdvocateFor Respondent: Dr. Darsi Suman Ratnam, CI

192,52 0.19 0.19 0.09 expenditure R&O revenue 5409.10 370742 1101,3.8 1492,86 746.42 208.42 104.21 expenditure Total 5,601.81 3900.34 1701.47 746.43 208.61 104.305 4. Without prejudice to Ground No. 3 above, in the facts and circumstances of the case, the learned C1T(A) further erred in stating amount of disallowance towards weighted portion of disallowance under

INTAS PHARMACEUTICALS LTD.,,AHMEDABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

ITA 1336/AHD/2017[2011-12]Status: DisposedITAT Ahmedabad31 Jan 2024AY 2011-12

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. AdvocateFor Respondent: Dr. Darsi Suman Ratnam, CI

192,52 0.19 0.19 0.09 expenditure R&O revenue 5409.10 370742 1101,3.8 1492,86 746.42 208.42 104.21 expenditure Total 5,601.81 3900.34 1701.47 746.43 208.61 104.305 4. Without prejudice to Ground No. 3 above, in the facts and circumstances of the case, the learned C1T(A) further erred in stating amount of disallowance towards weighted portion of disallowance under

THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1) (1),, AHMEDABAD vs. M/S. INTAS PHARMACEUTICALS PVT. LTD.,, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

ITA 1645/AHD/2017[2010-11]Status: DisposedITAT Ahmedabad31 Jan 2024AY 2010-11

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. AdvocateFor Respondent: Dr. Darsi Suman Ratnam, CI

192,52 0.19 0.19 0.09 expenditure R&O revenue 5409.10 370742 1101,3.8 1492,86 746.42 208.42 104.21 expenditure Total 5,601.81 3900.34 1701.47 746.43 208.61 104.305 4. Without prejudice to Ground No. 3 above, in the facts and circumstances of the case, the learned C1T(A) further erred in stating amount of disallowance towards weighted portion of disallowance under

JMC-MSKE(JV),,AHMEDABAD vs. INCOME TAX OFFICER, WARD-5(2)(3),, AHMEDABAD

In the result, appeal filed by the assessee in ITA no

ITA 829/AHD/2016[2010-11]Status: DisposedITAT Ahmedabad07 Nov 2024AY 2010-11

Bench: Us & That These Four

For Appellant: S/Sh. D.M. Rindani and Sh. Chintan Shah, RRsFor Respondent: Sh. Ashok Kumar Suthar, Sr. DR
Section 143(2)Section 143(3)Section 80

price as defined in clause (ii) of section 92F. (11) The Central Government may, after making such inquiry as it may think fit, direct, by notification in the Official Gazette, that the exemption conferred by this section shall not apply to any class of industrial undertaking or enterprise with effect from such date as it may specify in the notification

JMC-MSKE(JV),,AHMEDABAD vs. INCOME TAX OFFICER, WARD-5(2)(3),, AHMEDABAD

In the result, appeal filed by the assessee in ITA no

ITA 830/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad07 Nov 2024AY 2011-12

Bench: Us & That These Four

For Appellant: S/Sh. D.M. Rindani and Sh. Chintan Shah, RRsFor Respondent: Sh. Ashok Kumar Suthar, Sr. DR
Section 143(2)Section 143(3)Section 80

price as defined in clause (ii) of section 92F. (11) The Central Government may, after making such inquiry as it may think fit, direct, by notification in the Official Gazette, that the exemption conferred by this section shall not apply to any class of industrial undertaking or enterprise with effect from such date as it may specify in the notification

BGSCTPL- MSKEL CONSORTIUM,,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-10(1),, AHMEDABAD

In the result, appeal filed by the assessee in ITA no

ITA 2498/AHD/2013[2010-11]Status: DisposedITAT Ahmedabad07 Nov 2024AY 2010-11

Bench: Us & That These Four

For Appellant: S/Sh. D.M. Rindani and Sh. Chintan Shah, RRsFor Respondent: Sh. Ashok Kumar Suthar, Sr. DR
Section 143(2)Section 143(3)Section 80

price as defined in clause (ii) of section 92F. (11) The Central Government may, after making such inquiry as it may think fit, direct, by notification in the Official Gazette, that the exemption conferred by this section shall not apply to any class of industrial undertaking or enterprise with effect from such date as it may specify in the notification

BGSCTPL- MSKEL (JV),AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-5(2)(1),, AHMEDABAD

In the result, appeal filed by the assessee in ITA no

ITA 828/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad07 Nov 2024AY 2011-12

Bench: Us & That These Four

For Appellant: S/Sh. D.M. Rindani and Sh. Chintan Shah, RRsFor Respondent: Sh. Ashok Kumar Suthar, Sr. DR
Section 143(2)Section 143(3)Section 80

price as defined in clause (ii) of section 92F. (11) The Central Government may, after making such inquiry as it may think fit, direct, by notification in the Official Gazette, that the exemption conferred by this section shall not apply to any class of industrial undertaking or enterprise with effect from such date as it may specify in the notification

SUZLON ENERGY LTD.,,AHMEDABAD vs. THE ACIT(OSD) CIRCLE-8, AHMEDABAD

In the result the appeal filed by the Assessee in ITA No

ITA 1621/AHD/2019[2008-09]Status: DisposedITAT Ahmedabad29 Oct 2024AY 2008-09

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 143(3)Section 90

transfer pricing assessment for the above asst. years, thus there is no dispute by TPO in respect of the royalty income. However, the assessee company failed to claim the Foreign Tax Credit [herein after referred as FTC] under section 90 of the Act while filing the Return of Income as the Tax With-holding Certificates [TWC] were received

THE DCIT, CIRCLE-4(1)(1), AHMEDABAD vs. SUZLON ENERGY LTD., AHMEDABAD

In the result the appeal filed by the Assessee in ITA No

ITA 1517/AHD/2019[2008-09]Status: DisposedITAT Ahmedabad29 Oct 2024AY 2008-09

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 143(3)Section 90

transfer pricing assessment for the above asst. years, thus there is no dispute by TPO in respect of the royalty income. However, the assessee company failed to claim the Foreign Tax Credit [herein after referred as FTC] under section 90 of the Act while filing the Return of Income as the Tax With-holding Certificates [TWC] were received

THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD vs. SUZLON ENERGY LTD.,, AHMEDABAD

In the result the Ground Nos

ITA 302/AHD/2023[2016-17]Status: DisposedITAT Ahmedabad12 Nov 2024AY 2016-17

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 115JSection 143(3)Section 14A

192 (SC) and other decisions has held that it is incumbent upon it follow the decision of Hon'ble Delhi High Court in the case of Bhushan Steel. 17 I.T.A No. 198 & 199/Ahd/2023 & Ors. A.Ys. 2016-17 & 2017-18 Page No Suzlon Engergy Ltd. vs. DCIT In this case, Hon'ble Delhi High Court has held as under: “However

THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD vs. SUZLON ENERGY LTD.,, AHMEDABAD

In the result the Ground Nos

ITA 303/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad12 Nov 2024AY 2017-18

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 115JSection 143(3)Section 14A

192 (SC) and other decisions has held that it is incumbent upon it follow the decision of Hon'ble Delhi High Court in the case of Bhushan Steel. 17 I.T.A No. 198 & 199/Ahd/2023 & Ors. A.Ys. 2016-17 & 2017-18 Page No Suzlon Engergy Ltd. vs. DCIT In this case, Hon'ble Delhi High Court has held as under: “However

SUZLON ENERGY LTD.,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD

In the result the Ground Nos

ITA 198/AHD/2023[2016-17]Status: DisposedITAT Ahmedabad12 Nov 2024AY 2016-17

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 115JSection 143(3)Section 14A

192 (SC) and other decisions has held that it is incumbent upon it follow the decision of Hon'ble Delhi High Court in the case of Bhushan Steel. 17 I.T.A No. 198 & 199/Ahd/2023 & Ors. A.Ys. 2016-17 & 2017-18 Page No Suzlon Engergy Ltd. vs. DCIT In this case, Hon'ble Delhi High Court has held as under: “However

SUZLON ENERGY LTD.,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD

In the result the Ground Nos

ITA 199/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad12 Nov 2024AY 2017-18

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 115JSection 143(3)Section 14A

192 (SC) and other decisions has held that it is incumbent upon it follow the decision of Hon'ble Delhi High Court in the case of Bhushan Steel. 17 I.T.A No. 198 & 199/Ahd/2023 & Ors. A.Ys. 2016-17 & 2017-18 Page No Suzlon Engergy Ltd. vs. DCIT In this case, Hon'ble Delhi High Court has held as under: “However

INFIBEN AVENUES LTD (FORMERLY INFIBEAM INCORPORATION LTD.,,AHMEDABAD vs. THE PR. CIT-1, AHMEDABAD

In the result, the appeal of the assessee is allowed

ITA 108/AHD/2022[2017-18]Status: DisposedITAT Ahmedabad14 Oct 2024AY 2017-18

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Aseem L. Thakkar, A.RFor Respondent: Shri A.P. Singh, CIT DR
Section 143(3)Section 263Section 37

price and market value—qualifies as expenditure. The company submitted that the primary aim of granting Employee Stock Option Plans (ESOPs) is to ensure the consistent service of employees, which ultimately contributes to profitability, thus justifying the expense. Concerning the second condition mentioned, the company clarified that the expenditures incurred through ESOPs do not fall under sections

TORRENT PHARMACEUTICALS LTD.,,AHMEDABAD vs. ACIT, CIRCLE-4(1)(2),, AHMEDABAD

In the result appeal of the Revenue is hereby partly allowed

ITA 1172/AHD/2019[2015-16]Status: DisposedITAT Ahmedabad26 Feb 2024AY 2015-16

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

For Appellant: Shri Vartik Choksi, With Shri DhrunalBhatt, ARsFor Respondent: Shri Ritesh Parmar, CIT-DR
Section 143(3)Section 14ASection 35Section 43BSection 80

Transfer Pricing upward adjustment u/s.92CA(1) of the I.T Act as under: (a) Corporate Guarantee to Aes 8,32,291 (b) Capital Infusion to Aes 14,05,927 (c) Interest on Loan to Aes 4,39,625 Total: 26,77,843 10. On the facts and in the circumstances of the case, the learned CIT(Appeal) erred in confirming exclusion

M/S. BODAL CHEMICALS LTD.,AHMEDABAD vs. THE DY.CIT, CIRCLE-1, AHMEDABAD

In the result, the appeals being IT(SS)A No

ITA 318/AHD/2022[2009-10]Status: DisposedITAT Ahmedabad31 Jul 2025AY 2009-10

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

For Appellant: Shri S.S. Nagar, ARFor Respondent: Shri Kamlesh Makwana, CIT-DR and Shri B.P. Srivastava, Sr.DR
Section 115JSection 132(1)Section 139(1)Section 139(5)Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153A(1)(a)Section 153A(1)(b)

192 Less: Loans 62,376,684 Deferred tax Liabilities 19,283,770 81,660,454 ----------------------------------- 67,141,738 Less: Transfer of general reserve in books of Amalgamated company to general reserves of the company. 34,034,810 Transfer of investment allowance reserve in books of Amalgamated company to investment allowance reserve of the company 301,000 Transfer of balances

KOTHARI SANJAY MANILAL, HUF,AHMEDABAD vs. THE DCIT, CIRCLE-3(1)(1), AHMEDABAD

In the result, the appeal filed by the assessee is partly allowed

ITA 698/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad08 Nov 2024AY 2018-19

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. No. 698/Ahd/2024 ("नधा"रण वष" / Assessment Year : 2018-19)

For Appellant: & Shri Parin Shah, A.RFor Respondent: Date of Hearing
Section 143(3)Section 250Section 54FSection 57

price and until the said amount is paid by the society, each and every member will have the ownership right upon the property of the society allotted to him and from the date of making full payment of the said amount by the society, the allottee right of the members shall be relinquished and transferred in favour of the society