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4 results for “transfer pricing”+ Section 42clear

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Key Topics

Section 14810Section 143(2)9Section 143(3)6Section 1474Addition to Income4Section 69A3Section 683Section 1432Section 562

SANJAY MAJUMDAR,ALLAHABAD vs. PR. CIT, ALLAHABAD

ITA 68/ALLD/2018[2012-13]Status: DisposedITAT Allahabad28 Jan 2021AY 2012-13

Bench: Shri.Vijay Pal Rao & Shri Ramit Kocharassessment Year: 2012-13 Mr. Sanjay Majumdar, V. The Principal Commissioner Type Ii – 112, Devprayagam Of Income Tax, Sangam Vatika – Jhalwa, Aayakar Bhawan, Allahabad 211012 38, M.G. Marg, Civil Lines, Allahabad 211001 Pan: Adopm 2688P (Appellant) (Respondent)

For Appellant: Shri Basudev Banerjee, CAFor Respondent: Shri Debashish Chanda, CIT-DR
Section 147Section 154Section 263

price or the asset is made to grow better, vide CIT Vs Rama Swami Mudaliar (92) ITA No. 96 ITR 939 (MAD). Onus to prove the cost of improvement is on the assessee that he has incurred the improvement charges before transferring the asset. Section 48 is enabling provision, which permits certain deductions from the sale consideration received

M/S. GOVIND STONE PRIVATE LIMITED ,HAMIRPUR vs. INCOME TAX OFFICER -5(4), BANDA

Capital Gains2
Long Term Capital Gains2
Reassessment2
ITA 258/ALLD/2018[2013-14]Status: DisposedITAT Allahabad19 Dec 2022AY 2013-14

Bench: Shrivijay Pal Rao & Shri Ramit Kochar

For Appellant: Shri. R. S. Agrawal, Adv. &VinayGoel, C.AFor Respondent: Shri A.K. Singh Sr.D.R
Section 143Section 143(2)Section 143(3)Section 56Section 68

price of Rs. 90/- per equity share comprising face value of Rs. 10 per equity share and share premium of Rs. 80 per equity share, aggregating to total amount raised to the tune of Rs. 1,53,00,000/- . The additions u/s 68 read with Section 158BBE is made wrt 168000 equity shares issued to 5 corporate entities, while additions

ASHA TEWARI,MAHARAJGANJ vs. ITO, 1(4), MAHARAJGANJ

In the result, the appeal of the assessee is allowed

ITA 75/ALLD/2024[2017-18]Status: DisposedITAT Allahabad31 Dec 2024AY 2017-18

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2017-18 Asha Tewari, Vs. Income Tax Officer, Partawal, Maharajganj, U.P. Maharajganj Pan:Adjpt8320L (Appellant) (Respondent) Assessee By: Sh. Arvind Shukla, Advocate Revenue By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 23.10.2024 Date Of Pronouncement: 31.12.2024 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed Against The Order Of The Ld. Cit(A), Nfac, On 18.03.2024 Under Section 250 Of The Income Tax Act, 1961. The Grounds Of Appeal Preferred By The Assessee Are As Under: - “1. Because The Learned Authorities Below Have Erred In Law As Well As On Facts In Sustaining Addition Of Rs 21,55,000/- U/S 69A Which Actually Represented Receipts From Sale Of Petroleum Products Routed Through The Audited Books Of Accounts. 2. Because The Learned Cit(A) Has Erred In Sustaining Addition Of Rs 21,55,000/- U/S 69A Without Appreciating That The Said Section Is Not Applicable To The Facts Of The Case As The Entries Of Bank Deposits Are Flowing Directly From The Audited Books Of Accounts. 3. Because The Addition Of Rs 21,55,000/- Has Been Made & Sustained Simply On Negative Presumptions, Conjectures & Surmises To The Entire Exclusion Of Facts On Record. 4. Because The Learned Authorities Below Have Failed To Appreciate That During Demonetization Petrol Pumps Were Exempted From Taking Old Sbn & Hence There Was Nothing Unusual Or Incorrect With All Entries Routed Properly Through Audited Books Of Accounts.” 1 A.Y. 2017-18 Asha Tewari

For Appellant: Sh. Arvind Shukla, AdvocateFor Respondent: Sh. A.K. Singh, Sr. DR
Section 142(1)Section 250Section 69Section 69A

42,714/- had been made between 9th to 15th November, Rs.5,75,000/- had been made between 16th to 21st November, Rs.5,04,357/- was made between 22nd to 28th November and Rs.8,46,000/- was made between 29th to 30th November. He observed that the assessee had disclosed 2 A.Y. 2017-18 Asha Tewari total sales turnover of Rs.11

SHOBHA RASTOGI,ALLAHABAD vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1, ALLAHABAD

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 47/ALLD/2020[2008-09]Status: DisposedITAT Allahabad13 Aug 2021AY 2008-09

Bench: Shri.Vijay Pal Raoassessment Year: 2008-09 Smt. Shobha Rastogi, V. Deputy Commissioner Of Income 30-A, M.G. Marg, Civil Lines, Tax, Circle-1, Allahabad, U.P. Allahabad, U.P. Pan-Afqpr4774R (Appellant) (Respondent) Appellant By: Mr. Praveen Godbole, C.A. Respondent By: Mr. A.K. Singh, Sr. Dr Date Of Hearing: 12.08.2021 Date Of Pronouncement: 13.08.2021

For Appellant: Mr. Praveen Godbole, C.AFor Respondent: Mr. A.K. Singh, Sr. DR
Section 139(1)Section 143(2)Section 143(3)Section 147Section 148Section 50C

42,00,000/- (25,00,000+17,000,000), but the valuation of the property for stamp purchases was Rs. 79,55,000/- (45,86,000+33,69,000). Hence, in view of the provisions of section 50C of the Income Tax Act, 1961, I have reason to believe that income has escaped assessment for the AY under consideration