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440 results for “transfer pricing”+ Section 41(4)clear

Sorted by relevance

Delhi2,429Mumbai2,189Bangalore866Ahmedabad440Chennai412Karnataka361Kolkata354Hyderabad314Jaipur265Pune245Chandigarh195Indore176Surat150Cochin129Visakhapatnam62Calcutta57SC52Rajkot52Lucknow47Telangana45Cuttack45Raipur43Nagpur31Agra29Guwahati21Amritsar21Jodhpur18Rajasthan9Varanasi9Ranchi7A.K. SIKRI ROHINTON FALI NARIMAN6Allahabad5Orissa5Kerala5Dehradun4Panaji4DIPAK MISRA V. GOPALA GOWDA1Patna1T.S. THAKUR ROHINTON FALI NARIMAN1Andhra Pradesh1A.K. SIKRI N.V. RAMANA1

Key Topics

Section 143(3)67Disallowance60Addition to Income55Section 14A52Section 80I45Section 3729Penalty28Section 43B26Deduction25

ZYDUS LIFESCIENCES LIMITED (FORMERLY KNOWN AS CADILA HEALTHCARE LTD.),AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, appeal preferred by the assessee is allowed

ITA 162/AHD/2021[2016-17]Status: DisposedITAT Ahmedabad30 May 2024AY 2016-17

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 162/Ahd/2021 ("नधा"रण वष" / Assessment Years : 2016-17)

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 144BSection 144C(13)Section 153Section 92BSection 92C

4) of the Act, thereby making the transfer pricing order barred by limitation and invalid in law. In short, the order passed by the Ld. TPO under Section 92CA(3) of the Act is barred by limitation and thus bad in law, without jurisdiction and therefore, liable to be quashed. Consequently, the entire transfer pricing adjustment proposed by the Learned

Showing 1–20 of 440 · Page 1 of 22

...
Depreciation24
Limitation/Time-bar24
Section 8021

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

transferred to AAI(owner of the Airport) for operating and maintaining. Thus, it clearly shows that the AAI(Owner) has not imparted all the know-how and resources to the assessee so as to brand the assessee as a “works contractor”, but considerable resources and know-how were generated and deployed in the project from the side of the assessee

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

transferred to AAI(owner of the Airport) for operating and maintaining. Thus, it clearly shows that the AAI(Owner) has not imparted all the know-how and resources to the assessee so as to brand the assessee as a “works contractor”, but considerable resources and know-how were generated and deployed in the project from the side of the assessee

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

transferred to AAI(owner of the Airport) for operating and maintaining. Thus, it clearly shows that the AAI(Owner) has not imparted all the know-how and resources to the assessee so as to brand the assessee as a “works contractor”, but considerable resources and know-how were generated and deployed in the project from the side of the assessee

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

transferred to AAI(owner of the Airport) for operating and maintaining. Thus, it clearly shows that the AAI(Owner) has not imparted all the know-how and resources to the assessee so as to brand the assessee as a “works contractor”, but considerable resources and know-how were generated and deployed in the project from the side of the assessee

M/S. RANBAXY LABORATORIES LIMITED,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, the appeal of the assessee in IT(TP) A No

ITA 1782/DEL/2014[2009-10]Status: DisposedITAT Ahmedabad05 Sept 2019AY 2009-10

Bench: Justice P.P. Bhatt & Shri Waseem Ahmed1. आयकर अपील सं./It(Tp)A No. 1782/Del/2014 2. आयकर अपील सं./It(Tp)A No. 781/Del/2015 ("नधा"रण वष"/Assessment Years : 2009-10 & 2010-11) Ranbaxy Laboratories Ltd. The Dcit बनाम/ 12Th Floor, Devika Tower Circle-21(1), New Vs. 6, Nehru Place, New Delhi Delhi/ 110 019 Addl.Cit Range-15 New Delhi "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacr0127N .. (अपीलाथ"/Appellant) (""यथ" / Respondent) अपीलाथ" ओर से/ Appellant By : Shri S.N.Soparkar, Shri Vartik Chokshi, Ms.Urvashi Shodhan & Shri P.Shah, Ars ""यथ" क" ओर से/Respondent By: Shri Mahesh Shah, Cit-Dr

For Appellant: Shri S.N.Soparkar, Shri Vartik ChokshiFor Respondent: Shri Mahesh Shah, CIT-DR
Section 143(3)Section 144CSection 92D

Pricing ('TP') documentation maintained by it in terms of section 92D of the Act read with Rule 10D of the Income-tax Rules, 1962 ('Rules'); 2.2 not accepting the overseas Associated Enterprises ('AEs') as the tested party, being the least complex of the transacting entities and instead considering the appellant as the tested party, thus violating the basic principles

RANBAXY LABORATORIES LTD.,DELHI vs. DCIT, NEW DELHI

In the result, the appeal of the assessee in IT(TP) A No

ITA 781/DEL/2015[2010-11]Status: DisposedITAT Ahmedabad05 Sept 2019AY 2010-11

Bench: Justice P.P. Bhatt & Shri Waseem Ahmed1. आयकर अपील सं./It(Tp)A No. 1782/Del/2014 2. आयकर अपील सं./It(Tp)A No. 781/Del/2015 ("नधा"रण वष"/Assessment Years : 2009-10 & 2010-11) Ranbaxy Laboratories Ltd. The Dcit बनाम/ 12Th Floor, Devika Tower Circle-21(1), New Vs. 6, Nehru Place, New Delhi Delhi/ 110 019 Addl.Cit Range-15 New Delhi "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacr0127N .. (अपीलाथ"/Appellant) (""यथ" / Respondent) अपीलाथ" ओर से/ Appellant By : Shri S.N.Soparkar, Shri Vartik Chokshi, Ms.Urvashi Shodhan & Shri P.Shah, Ars ""यथ" क" ओर से/Respondent By: Shri Mahesh Shah, Cit-Dr

For Appellant: Shri S.N.Soparkar, Shri Vartik ChokshiFor Respondent: Shri Mahesh Shah, CIT-DR
Section 143(3)Section 144CSection 92D

Pricing ('TP') documentation maintained by it in terms of section 92D of the Act read with Rule 10D of the Income-tax Rules, 1962 ('Rules'); 2.2 not accepting the overseas Associated Enterprises ('AEs') as the tested party, being the least complex of the transacting entities and instead considering the appellant as the tested party, thus violating the basic principles

THE ACIT, CIRCLE-5,, AHMEDABAD vs. RAJKAMAL BUILDER INFRASTRUCTURE PVT. LTD,, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 1966/AHD/2012[2007-08]Status: DisposedITAT Ahmedabad13 May 2022AY 2007-08

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

price escalation in respect of material, labour, which may be caused due to inflation and for these precise reason the assessee has suffered huge loss in the development of main projects as reflected in the materials placed before us. A look at these figures would carry the aspect of the financial risk involved in the various projects undertaken

M/S. RAJKAMAL BUILDERS INFRASTRUCTURE PVT. LTD,,AHMEDABAD vs. THE ACIT, CIRCLE-5,, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 2334/AHD/2014[2011-12]Status: DisposedITAT Ahmedabad13 May 2022AY 2011-12

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

price escalation in respect of material, labour, which may be caused due to inflation and for these precise reason the assessee has suffered huge loss in the development of main projects as reflected in the materials placed before us. A look at these figures would carry the aspect of the financial risk involved in the various projects undertaken

M/S. RAJKAMAL BUILDERS INFRASTRUCTURE PVT. LTD.,,AHMEDABAD vs. THE ACIT, CIRCLE-3(1)(2),, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 1281/AHD/2016[2012-13]Status: DisposedITAT Ahmedabad13 May 2022AY 2012-13

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

price escalation in respect of material, labour, which may be caused due to inflation and for these precise reason the assessee has suffered huge loss in the development of main projects as reflected in the materials placed before us. A look at these figures would carry the aspect of the financial risk involved in the various projects undertaken

RAJKAMAL BUILDER INFRASTRUCTURE PVT. LTD,,AHMEDABAD vs. THE DY.CIT., CIRCLE-5,, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 442/AHD/2011[2007-08]Status: DisposedITAT Ahmedabad13 May 2022AY 2007-08

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

price escalation in respect of material, labour, which may be caused due to inflation and for these precise reason the assessee has suffered huge loss in the development of main projects as reflected in the materials placed before us. A look at these figures would carry the aspect of the financial risk involved in the various projects undertaken

M/S. RAJKAMAL BUILDERS INFRASTRUCTURE PVT. LTD.,,AHMEDABAD vs. THE ACIT., CIRCLE-3(1)(2),, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 2916/AHD/2016[2013-14]Status: DisposedITAT Ahmedabad13 May 2022AY 2013-14

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

price escalation in respect of material, labour, which may be caused due to inflation and for these precise reason the assessee has suffered huge loss in the development of main projects as reflected in the materials placed before us. A look at these figures would carry the aspect of the financial risk involved in the various projects undertaken

M/S. RAJKAMAL BUILDERS INFRASTRUCTURE PVT. LTD.,,AHMEDABAD vs. THE DCIT, CIRCLE-3(1)(2),, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 2201/AHD/2018[2015-16]Status: DisposedITAT Ahmedabad13 May 2022AY 2015-16

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

price escalation in respect of material, labour, which may be caused due to inflation and for these precise reason the assessee has suffered huge loss in the development of main projects as reflected in the materials placed before us. A look at these figures would carry the aspect of the financial risk involved in the various projects undertaken

M/S. RAJKAMAL BUILDER INFRASTRUCTURE PVT. LTD,,AHMEDABAD vs. THE DY.CIT., CIRCLE-5,, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 118/AHD/2009[2002-03]Status: DisposedITAT Ahmedabad13 May 2022AY 2002-03

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

price escalation in respect of material, labour, which may be caused due to inflation and for these precise reason the assessee has suffered huge loss in the development of main projects as reflected in the materials placed before us. A look at these figures would carry the aspect of the financial risk involved in the various projects undertaken

THE DCIT, CIRCLE-5,, AHMEDABAD vs. RAJKAMAL BUILDER INFRASTRUCTURE PVT. LTD,, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 722/AHD/2010[2006-07]Status: DisposedITAT Ahmedabad13 May 2022AY 2006-07

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

price escalation in respect of material, labour, which may be caused due to inflation and for these precise reason the assessee has suffered huge loss in the development of main projects as reflected in the materials placed before us. A look at these figures would carry the aspect of the financial risk involved in the various projects undertaken

THE ACIT, CIRCLE-5,, AHMEDABAD vs. M/S. RAJKAMAL BUILDER INFRASTRUCTURE PVT. LTD,, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 199/AHD/2016[2009-10]Status: DisposedITAT Ahmedabad13 May 2022AY 2009-10

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

price escalation in respect of material, labour, which may be caused due to inflation and for these precise reason the assessee has suffered huge loss in the development of main projects as reflected in the materials placed before us. A look at these figures would carry the aspect of the financial risk involved in the various projects undertaken

THE DCIT, CIRCLE-5,, AHMEDABAD vs. RAJKAMAL BUILDER INFRASTRUCTURE PVT. LTD,, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 2489/AHD/2009[2005-06]Status: DisposedITAT Ahmedabad13 May 2022AY 2005-06

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

price escalation in respect of material, labour, which may be caused due to inflation and for these precise reason the assessee has suffered huge loss in the development of main projects as reflected in the materials placed before us. A look at these figures would carry the aspect of the financial risk involved in the various projects undertaken

RAJKAMAL BUILDER INFRASTRUCTURE PVT. LTD,,AHMEDABAD vs. THE ADDL.CIT., RANGE-5,, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 3254/AHD/2011[2008-09]Status: DisposedITAT Ahmedabad13 May 2022AY 2008-09

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

price escalation in respect of material, labour, which may be caused due to inflation and for these precise reason the assessee has suffered huge loss in the development of main projects as reflected in the materials placed before us. A look at these figures would carry the aspect of the financial risk involved in the various projects undertaken

M/S. RAJKAMAL BUILDERS INFRASTRUCTURE PVT. LTD.,,AHMEDABAD vs. THE DCIT, CIRCLE-3(1)(2),, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 2202/AHD/2018[2016-17]Status: DisposedITAT Ahmedabad13 May 2022AY 2016-17

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

price escalation in respect of material, labour, which may be caused due to inflation and for these precise reason the assessee has suffered huge loss in the development of main projects as reflected in the materials placed before us. A look at these figures would carry the aspect of the financial risk involved in the various projects undertaken

M/S. RAJKAMAL BUILDERS INFRASTRUCTURE PVT. LTD.,,AHMEDABAD vs. THE ACIT., CIRCLE-3(1)(2),, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 2917/AHD/2016[2010-11]Status: DisposedITAT Ahmedabad13 May 2022AY 2010-11

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

price escalation in respect of material, labour, which may be caused due to inflation and for these precise reason the assessee has suffered huge loss in the development of main projects as reflected in the materials placed before us. A look at these figures would carry the aspect of the financial risk involved in the various projects undertaken