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14 results for “transfer pricing”+ Section 253(2)clear

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Key Topics

Section 80I18Section 143(3)17Addition to Income12Section 686Section 69C4Deduction4Disallowance4Section 2503Section 143(2)3

SANDEEP MOHANRAJ SINGHI,AHMEDABAD vs. ACIT, CIRCLE4(2), AHMEDABAD, AHMEDABAD

In the result, appeal of the assessee is partly allowed

ITA 769/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad07 Jan 2025AY 2015-16

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaassessment Year: 2018-19

Section 11Section 12ASection 143(3)Section 147Section 68

price of Rs.673/- per share. When the sale transactions made by Shri Pratul Krishnakant Shroff, the trustee, was held as genuine and accepted by the Department in the assessment order completed in his case, there was no reason to take a divergent view in the case of the assessee. We, therefore, do not find any rationale for the action

DR K R SHROFF FOUNDATION,AHMEDABAD vs. THE DY. CIT, CIRCLE-1, EXMP, AHMEDABAD

Section 803
Section 115J3
Charitable Trust3

In the result, appeal of the assessee is partly allowed\n\n29

ITA 769/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad05 Aug 2025AY 2018-19
Section 11Section 12ASection 143(3)Section 147Section 68

price of Rs.673/- per share.\nWhen the sale transactions made by Shri Pratul Krishnakant Shroff, the\ntrustee, was held as genuine and accepted by the Department in the\nassessment order completed in his case, there was no reason to take a\ndivergent view in the case of the assessee. We, therefore, do not find any\nrationale for the action

ACIT (EXEMPTION) CIRCLE 1 AHMEDABAD, AHMEDABAD vs. DR K R SHROFF FOUNDATION, AHMEDABAD

In the result, appeal of the assessee is partly allowed\n\n29

ITA 1205/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad05 Aug 2025AY 2018-19
Section 11Section 12ASection 143(3)Section 147Section 68

price of Rs.673/- per share.\nWhen the sale transactions made by Shri Pratul Krishnakant Shroff, the\ntrustee, was held as genuine and accepted by the Department in the\nassessment order completed in his case, there was no reason to take a\ndivergent view in the case of the assessee. We, therefore, do not find any\nrationale for the action

THE ACIT.(OSD), CIRCLE-1,, AHMEDABAD vs. KHURANA ENGINEERING LTD.,, AHMEDABAD

ITA 2308/AHD/2011[2007-08]Status: DisposedITAT Ahmedabad19 Apr 2024AY 2007-08

Bench: Shri Ramit Kochar & Ms. Madhumita Roya.Y. 2007-08

For Appellant: Sh. S.N. Soparkar, Sr. Advocate & Sh. ParinFor Respondent: Sh. Chetram Meena, Sr. DR
Section 143(2)Section 143(3)Section 80I

price that such goods or services would ordinarily fetch in the open market.] (9) Where any amount of profits and gains of an 76[undertaking]or of an enterprise in the case of an assessee is claimed and allowed under this section for any assessment year, deduction to the extent of such profits and gains shall not be allowed under

KHURANA ENGINEERING LTD.,,AHMEDABAD vs. THE ACIT.(OSD),CIRCLE-1,, AHMEDABAD

ITA 2357/AHD/2011[2008-09]Status: DisposedITAT Ahmedabad19 Apr 2024AY 2008-09

Bench: Shri Ramit Kochar & Ms. Madhumita Roya.Y. 2007-08

For Appellant: Sh. S.N. Soparkar, Sr. Advocate & Sh. ParinFor Respondent: Sh. Chetram Meena, Sr. DR
Section 143(2)Section 143(3)Section 80I

price that such goods or services would ordinarily fetch in the open market.] (9) Where any amount of profits and gains of an 76[undertaking]or of an enterprise in the case of an assessee is claimed and allowed under this section for any assessment year, deduction to the extent of such profits and gains shall not be allowed under

THE ACIT.(OSD), CIRCLE-1,, AHMEDABAD vs. KHURANA ENGINEERING LTD.,, AHMEDABAD

ITA 2352/AHD/2011[2008-09]Status: DisposedITAT Ahmedabad19 Apr 2024AY 2008-09

Bench: Shri Ramit Kochar & Ms. Madhumita Roya.Y. 2007-08

For Appellant: Sh. S.N. Soparkar, Sr. Advocate & Sh. ParinFor Respondent: Sh. Chetram Meena, Sr. DR
Section 143(2)Section 143(3)Section 80I

price that such goods or services would ordinarily fetch in the open market.] (9) Where any amount of profits and gains of an 76[undertaking]or of an enterprise in the case of an assessee is claimed and allowed under this section for any assessment year, deduction to the extent of such profits and gains shall not be allowed under

BOCK COMPRESSORS INDIA PRIVATE,BENGALURU vs. THE DY. CIT, CIRCLE - 1(1)(1), VADODARA

In the result, the appeal of the assessee is partly allowed

ITA 1484/AHD/2024[2020-21]Status: DisposedITAT Ahmedabad09 May 2025AY 2020-21

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarassessment Year 2020-21

For Appellant: Shri Ketan Ves, A.R. &For Respondent: Shri Uday Kakne, Sr. D.R
Section 143(3)Section 144(5)Section 144CSection 234BSection 253Section 270ASection 920Section 92ASection 92C

section 253 of the Income-tax Act. 1961 (the Act ) against the order passed by Assessment Unit, Income Tax Department (Assessing Officer" or "AO") dated 27 June 2024 in pursuance of the Directions issued by the Dispute Resolution Panel ("DRP") 2, Mumbai dated 24 May 2024, on the following grounds: I.T.A No. 1484/Ahd/2024 Bock Compressors India

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

2 per cent. We observe that in the instant facts, the assessee has computed the ALP at LIBOR plus 2.5%. The Ld. CIT(Appeals) has upheld the order of the Ld. Assessing Officer on the Ground that the assessee has not given the comparable basis for arriving at the aforesaid rate. However, in our view, the Ld. CIT(Appeals

THE ITO, WARD-3(3)(12),, AHMEDABAD vs. SHRI CAWAS DARASHA KARAKA, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

ITA 499/AHD/2018[2013-14]Status: DisposedITAT Ahmedabad08 Apr 2025AY 2013-14

Bench: DR. B.R.R. KUMAR, VICE-PRESIDENT\nMS. SUCHITRA KAMBLE, JUDICIAL MEMBER\nI.T.A. No. 499/Ahd/2018\n(Assessment Year: 2013-14)\nIncome-Tax Officer,\nWard-3(3)(12),\nAhmedabad\n(Appellant)\nVs.\nLate Shri Cawas Darasha\nKaraka, Legal Heir M/s.\nCawas Karaka Trust,\n22, Teen Murti Bungalows,\nNr. Devang Bungalows,\nThaltej, Ahmedabad-380054\n[PAN : AGSPK 9616 L]\n(Respondent)\nAppellant by :\nShri Tushar Hemani, Sr. Advocate &\nShri Parimalsinh H. Parmar, ARs\nRespondent by:\nAdjournment applica

For Appellant: \nShri Tushar Hemani, Sr. Advocate &For Respondent: \nAdjournment application filed
Section 143(3)Section 250Section 48Section 49(1)Section 55(2)(a)Section 69A

price paid or promised, or of\nmoney, a share of crops, service or any other thing of value, to be rendered\nperiodically or on specified occasions to the transfer by the transferee, who\naccepts the transfer on such terms.\n2.\nIt is most humbly submitted that the land admeasuring 3 acres and\n33 gunthas was demised by the said

SHRI MUKESH RASIKLAL SHAH,,AHMEDABAD vs. THE ACIT, CIRCLE-9, NOW CIRCLE-4(2),, AHMEDABAD

In the result, the appeals filed by the assessee are hereby dismissed

ITA 3217/AHD/2015[1992-93]Status: DisposedITAT Ahmedabad31 Dec 2024AY 1992-93

Bench: Dr. B.R.R. Kumar, Vice-Shri T.R. Senthil Kumar

For Appellant: Shri Mukesh R. Shah – Party in personFor Respondent: Shri Karun Kant Ojha, CIT-DR
Section 132Section 153Section 250

253 pages), 28-11-2006, and thus overruled the directions of Hon’ble ITAT. VI (17) That learned ACIT ought to have appreciated that alleged income tax refund money receipts, which belongs to Govt. of India, and hence recovered fully with interest, does not constitute income chargeable to tax u/s. 2 (24)/U/s. 4 r.w. other sections

SHRI MUKESH RASIKLAL SHAH,,AHMEDABAD vs. THE ACIT, CIRCLE-9, NOW CIRCLE-4(2),, AHMEDABAD

In the result, the appeals filed by the assessee are hereby dismissed

ITA 3218/AHD/2015[1993-94]Status: DisposedITAT Ahmedabad31 Dec 2024AY 1993-94

Bench: Dr. B.R.R. Kumar, Vice-Shri T.R. Senthil Kumar

For Appellant: Shri Mukesh R. Shah – Party in personFor Respondent: Shri Karun Kant Ojha, CIT-DR
Section 132Section 153Section 250

253 pages), 28-11-2006, and thus overruled the directions of Hon’ble ITAT. VI (17) That learned ACIT ought to have appreciated that alleged income tax refund money receipts, which belongs to Govt. of India, and hence recovered fully with interest, does not constitute income chargeable to tax u/s. 2 (24)/U/s. 4 r.w. other sections

THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD vs. SHRI SANJAY KISHANLAL BISHNOI,, AHMEDABAD

ITA 297/AHD/2021[2015-16]Status: DisposedITAT Ahmedabad10 Apr 2024AY 2015-16

Bench: Shri Ramit Kochar & Ms. Suchitra Kamble

For Appellant: Sh. Umedsingh Bhati & Sh. Abhimanyu SinghFor Respondent: Sh. Subhendu Das, CIT, DR
Section 143(3)Section 145(3)Section 253(3)Section 69C

253(3) of the 1961 Act. The Revenue has claimed that in view of extension of period of limitation by Hon’ble Supreme Court owing to Pandemic Covid-19 in Suo Motu Writ Petition(C) No. 3 of 2020 , wherein Hon’ble Supreme Court extended the period of limitation for filing appeals, there

THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD vs. SHRI SANJAY KISHANLAL BISHNOI,, AHMEDABAD

ITA 296/AHD/2021[2014-15]Status: DisposedITAT Ahmedabad10 Apr 2024AY 2014-15

Bench: Shri Ramit Kochar & Ms. Suchitra Kamble

For Appellant: Sh. Umedsingh Bhati & Sh. Abhimanyu SinghFor Respondent: Sh. Subhendu Das, CIT, DR
Section 143(3)Section 145(3)Section 253(3)Section 69C

253(3) of the 1961 Act. The Revenue has claimed that in view of extension of period of limitation by Hon’ble Supreme Court owing to Pandemic Covid-19 in Suo Motu Writ Petition(C) No. 3 of 2020 , wherein Hon’ble Supreme Court extended the period of limitation for filing appeals, there

AMBALAL SARABHAI ENTERPRISES LTD.,,BARODA vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX-1,, BARODA

In the result, appeal filed by the assessee is allowed

ITA 903/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad18 Feb 2026AY 2011-12

Bench: The Itat. Considering The Same, The Order Passed By Itat Was Recalled & The Appeal Of The Assessee Fixed For Adjudication Afresh On Merits, Vide Order In Ma No.94/Ahd/2025, Dated 18.12.2025. The Present Appeal, Accordingly, Has Come Up For Hearing Before Us.

For Appellant: Shri Bandish Soparkar, ARFor Respondent: Shri Alpesh Parmar, CIT.DR
Section 115JSection 143(3)Section 263

Section 263 of the ITA No.903/Ahd/2016 [Ambalal Sarabhai Enterprises Ltd. vs. PCIT] A.Y. 2011-12 - 2 – Income Tax Act, 1961 (hereinafter referred to as the “Act”) and relates to Assessment Year (A.Y.) 2011-12. 2. The order in the present appeal was originally passed vide order dated 25.06.2025 dismissing the appeal as infructuous noting that no consequential order had been