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34 results for “transfer pricing”+ Section 274clear

Sorted by relevance

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Key Topics

Section 3727Section 26318Disallowance16Addition to Income15Penalty15Section 143(3)14Section 14710Limitation/Time-bar10Section 90(2)

ZYDUS LIFESCIENCES LTD.,AHMEDABAD vs. THE DY.CIT, CENTRAL CIRCLE-2(1), AHMEDABAD

In the result, appeal filed by the assessee is partly allowed for statistical purposes

ITA 392/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad29 Jan 2026AY 2017-18

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), Ms. SUCHITRA KAMBLE (Judicial Member)

For Appellant: Shri Mukesh Patel, Shri Ajit KumarFor Respondent: Shri Prathvi Raj Meena, CIT.DR
Section 153(4)Section 153CSection 35Section 35(1)(i)Section 35(1)(iv)Section 92CSection 92C(2)

Transfer Pricing Officer (TPO) has erred in law and on facts in exceeding the jurisdiction by passing the TP Order under Section 92CA(3) of the Income-tax Act, 1961 (the Act) beyond the mandatorily prescribed time limit as per Section 92CA(3A) read with Section 153(4) of the Act, thereby making the TP Order barred by limitation

Showing 1–20 of 34 · Page 1 of 2

9
Section 234A9
Section 2349
Section 271(1)(c)9

PRIYA BLUE INDUSTRIES PVT.LTD.,BHAVNAGAR vs. THE DY.CIT., CENTRAL CIRCLE-1(1),, AHMEDABAD

In the result, appeal filed by the assessee is allowed

ITA 75/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad16 Jan 2025AY 2016-17

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

Section 132Section 143(3)Section 153ASection 250Section 271BSection 273BSection 92E

274 ITR 562 (Guj) - CIT vs. Xavier Kelavani Mandal P. Ltd. – 221 Taxman 43 (Guj) - Zenith Processing Mills vs. CIT – 219 ITR 721 (Guj) 5.1 The Ld. AR further submitted that penalty under Section 271BA of the Act cannot be levied merely for a technical default. Penalty is unwarranted in view of reasonable cause as per Section 273B

N.K. INDUSTRIES LTD.,AHMEDABAD vs. THE DY.CIT, CIRCLE-3(1)(1), AHMEDABAD

In the result, the appeal of the assessee on this ground is allowed

ITA 448/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad25 Apr 2025AY 2013-14

Bench: Dr. B.R.R. Kumarms. Suchitra Kamble

For Appellant: NK Industries Ltd (Cross Appeals)
Section 250

274 (KB)], wherein the Bench distinguished the decision in Morley. On the basis of the said opinion, the Supreme Court held that the assessee became richer, by the amount, which it transferred to its profit and loss account and that those monies had arisen out of ordinary trading transactions. The Supreme Court observed that although the amounts received originally were

N.K. INDUSTRIES LTD.,AHMEDABAD vs. THE DY.CIT, CIRCLE-3(1)(1), AHMEDABAD

In the result, the appeal of the assessee on this ground is allowed

ITA 447/AHD/2023[2010-11]Status: DisposedITAT Ahmedabad25 Apr 2025AY 2010-11

Bench: Dr. B.R.R. Kumarms. Suchitra Kamble

For Appellant: NK Industries Ltd (Cross Appeals)
Section 250

274 (KB)], wherein the Bench distinguished the decision in Morley. On the basis of the said opinion, the Supreme Court held that the assessee became richer, by the amount, which it transferred to its profit and loss account and that those monies had arisen out of ordinary trading transactions. The Supreme Court observed that although the amounts received originally were

THE DY.CIT, CIRCLE-3(1)(1)., AHMEDABAD vs. N.K. INDUSTRIES LTD., AHMEDABAD

In the result, the appeal of the assessee on this ground is allowed

ITA 443/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad25 Apr 2025AY 2013-14

Bench: Dr. B.R.R. Kumarms. Suchitra Kamble

For Appellant: NK Industries Ltd (Cross Appeals)
Section 250

274 (KB)], wherein the Bench distinguished the decision in Morley. On the basis of the said opinion, the Supreme Court held that the assessee became richer, by the amount, which it transferred to its profit and loss account and that those monies had arisen out of ordinary trading transactions. The Supreme Court observed that although the amounts received originally were

THE DY.CIT, CIRCLE-3(1)(1)., AHMEDABAD vs. N.K. INDUSTRIES LTD., AHMEDABAD

In the result, the appeal of the assessee on this ground is allowed

ITA 442/AHD/2023[2010-11]Status: DisposedITAT Ahmedabad25 Apr 2025AY 2010-11

Bench: Dr. B.R.R. Kumarms. Suchitra Kamble

For Appellant: NK Industries Ltd (Cross Appeals)
Section 250

274 (KB)], wherein the Bench distinguished the decision in Morley. On the basis of the said opinion, the Supreme Court held that the assessee became richer, by the amount, which it transferred to its profit and loss account and that those monies had arisen out of ordinary trading transactions. The Supreme Court observed that although the amounts received originally were

SHRIKANTSINGH RAMDAYAL SHAKYA,BHARATPUR vs. THE PCIT, VADODARA-1, VADODARA

In the result, the appeal filed by all the nine assessees is dismissed

ITA 469/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad27 May 2024AY 2018-19

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

Section 143(3)Section 17(1)Section 263

Transfer Pricing Officer, as the case may be,] shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner,— (a) the order is passed without making inquiries or verification which should have been made

MAFATBHAI BHIKHABHAI PARMAR,BHARATPUR vs. THE PCIT, VADODARA-1, VADODARA

In the result, the appeal filed by all the nine assessees is dismissed

ITA 463/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad27 May 2024AY 2018-19

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

Section 143(3)Section 17(1)Section 263

Transfer Pricing Officer, as the case may be,] shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner,— (a) the order is passed without making inquiries or verification which should have been made

JITENDRA KUMAR SHIMPI,BHARATPUR vs. THE PCIT, VADODARA-1, VADODARA

In the result, the appeal filed by all the nine assessees is dismissed

ITA 464/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad27 May 2024AY 2018-19

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

Section 143(3)Section 17(1)Section 263

Transfer Pricing Officer, as the case may be,] shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner,— (a) the order is passed without making inquiries or verification which should have been made

MAHENDRA AMBALAL ROHIT,BHARATPUR vs. THE PCIT, VADODARA-1, VADODARA

In the result, the appeal filed by all the nine assessees is dismissed

ITA 465/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad27 May 2024AY 2018-19

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

Section 143(3)Section 17(1)Section 263

Transfer Pricing Officer, as the case may be,] shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner,— (a) the order is passed without making inquiries or verification which should have been made

IMTIYAZ KARIMBHAI VHORA,BHARATPUR vs. THE PCIT, VADODARA-1, VADODARA

In the result, the appeal filed by all the nine assessees is dismissed

ITA 466/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad27 May 2024AY 2018-19

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

Section 143(3)Section 17(1)Section 263

Transfer Pricing Officer, as the case may be,] shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner,— (a) the order is passed without making inquiries or verification which should have been made

BHARATSINGH AMARSINGH RAJPUT,BHARATPUR vs. THE PCIT, VADODARA-1, VADODARA

In the result, the appeal filed by all the nine assessees is dismissed

ITA 467/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad27 May 2024AY 2018-19

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

Section 143(3)Section 17(1)Section 263

Transfer Pricing Officer, as the case may be,] shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner,— (a) the order is passed without making inquiries or verification which should have been made

WILSON MIKHAEL TOPNO,BHARATPUR vs. THE PCIT, VADODARA-1, VADODARA

In the result, the appeal filed by all the nine assessees is dismissed

ITA 468/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad27 May 2024AY 2018-19

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

Section 143(3)Section 17(1)Section 263

Transfer Pricing Officer, as the case may be,] shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner,— (a) the order is passed without making inquiries or verification which should have been made

ANKIT PRANLAL PATEL,BHARATPUR vs. THE PCIT, VADODARA-1, VADODARA

In the result, the appeal filed by all the nine assessees is dismissed

ITA 470/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad27 May 2024AY 2018-19

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

Section 143(3)Section 17(1)Section 263

Transfer Pricing Officer, as the case may be,] shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner,— (a) the order is passed without making inquiries or verification which should have been made

ARBINDA KUMAR SINGH,BHARATPUR vs. THE PCIT, VADODARA-1, VADODARA

In the result, the appeal filed by all the nine assessees is dismissed

ITA 471/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad27 May 2024AY 2018-19

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

Section 143(3)Section 17(1)Section 263

Transfer Pricing Officer, as the case may be,] shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner,— (a) the order is passed without making inquiries or verification which should have been made

THE ACIT, CIRCLE-1(1)(1), VADODARA vs. SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 147/AHD/2023[2010-11]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2010-11

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

274 ITR (Stat) 74; Indo Hungarian tax treaty, in short], it is specifically provided, In the protocol to the Indo Hungarian tax treaty it is specifically stated that "When the company paying the dividends is a resident of India the tax on distributed profits shall be deemed to be taxed in the hands of the shareholders and it shall

THE ACIT, CIRCLE-1(1)(1), VADODARA vs. SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 148/AHD/2023[2011-12]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2011-12

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

274 ITR (Stat) 74; Indo Hungarian tax treaty, in short], it is specifically provided, In the protocol to the Indo Hungarian tax treaty it is specifically stated that "When the company paying the dividends is a resident of India the tax on distributed profits shall be deemed to be taxed in the hands of the shareholders and it shall

THE ACIT, CIRCLE-1(1)(1), VADODARA vs. SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 149/AHD/2023[2012-13]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2012-13

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

274 ITR (Stat) 74; Indo Hungarian tax treaty, in short], it is specifically provided, In the protocol to the Indo Hungarian tax treaty it is specifically stated that "When the company paying the dividends is a resident of India the tax on distributed profits shall be deemed to be taxed in the hands of the shareholders and it shall

SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.),VADODARA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(2) NOW CIRCLE-1(1)(1), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 133/AHD/2023[2010-11]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2010-11

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

274 ITR (Stat) 74; Indo Hungarian tax treaty, in short], it is specifically provided, In the protocol to the Indo Hungarian tax treaty it is specifically stated that "When the company paying the dividends is a resident of India the tax on distributed profits shall be deemed to be taxed in the hands of the shareholders and it shall

SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.),VADODARA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2) NOW CIRCLE-1(1)(1), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 134/AHD/2023[2011-12]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2011-12

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

274 ITR (Stat) 74; Indo Hungarian tax treaty, in short], it is specifically provided, In the protocol to the Indo Hungarian tax treaty it is specifically stated that "When the company paying the dividends is a resident of India the tax on distributed profits shall be deemed to be taxed in the hands of the shareholders and it shall