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55 results for “transfer pricing”+ Section 1clear

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Key Topics

Section 26358Section 143(3)53Addition to Income47Section 153(4)28Section 14824Section 6916Section 13215Section 10B14Section 25014

SATIA INDUSTRIES LIMITED,MUKTSAR, PUNJAB vs. DCIT, ACIT CIRCLE 1, BATHINDA

In the result, the appeal is partly allowed

ITA 527/ASR/2024[2020-21]Status: DisposedITAT Amritsar28 Feb 2025AY 2020-21

Bench: Shri Udayan Das Gupta & Shri Krinwant Sahayआयकरअपीलसं./Ita No. 527/Asr/2024 िनधा"रणवष" / Assessment Year : 2020-21

For Appellant: S/Shri Sudhir SehgalFor Respondent: Shri K. Mehboob Ali Khan, CIT DR
Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)Section 80

transfer pricing adjustments. 5.2 The assessee has established two captive electricity and steam generation units (referred to as Co-generation Unit 1 and Co- generation Unit 2) located in Muktsar, Punjab, for the generation of electricity and steam. The assessee has sought exemption under Section

Showing 1–20 of 55 · Page 1 of 3

Disallowance12
Search & Seizure9
Exemption8

THE ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAYS OVERSEAS LTD, JALANDHAR

ITA 477/ASR/2015[2008-09]Status: DisposedITAT Amritsar30 May 2023AY 2008-09

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 10BSection 14A

section 143(1) of the Act at the same income vide order dated 21.03.2009. During the course of assessment proceedings, the Assessing Officer has noticed that International Transactions of the assessee company with its Associate Enterprise during the year under consideration exceeds Rs. 15,00,00,000/- and hence, it required reference to Transfer Pricing

THE ASSTT. COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAYS OVERSEAS LTD, JALANDHAR

ITA 345/ASR/2016[2012-13]Status: DisposedITAT Amritsar30 May 2023AY 2012-13

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 10BSection 14A

section 143(1) of the Act at the same income vide order dated 21.03.2009. During the course of assessment proceedings, the Assessing Officer has noticed that International Transactions of the assessee company with its Associate Enterprise during the year under consideration exceeds Rs. 15,00,00,000/- and hence, it required reference to Transfer Pricing

THE ASSTT. COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAY OVERSEAS LTD., JALANDHAR

ITA 46/ASR/2016[2007-08]Status: DisposedITAT Amritsar30 May 2023AY 2007-08

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 10BSection 14A

section 143(1) of the Act at the same income vide order dated 21.03.2009. During the course of assessment proceedings, the Assessing Officer has noticed that International Transactions of the assessee company with its Associate Enterprise during the year under consideration exceeds Rs. 15,00,00,000/- and hence, it required reference to Transfer Pricing

THE ASSTT. COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAY OVERSEAS LTD., JALANDHAR

ITA 48/ASR/2016[2010-11]Status: DisposedITAT Amritsar30 May 2023AY 2010-11

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 10BSection 14A

section 143(1) of the Act at the same income vide order dated 21.03.2009. During the course of assessment proceedings, the Assessing Officer has noticed that International Transactions of the assessee company with its Associate Enterprise during the year under consideration exceeds Rs. 15,00,00,000/- and hence, it required reference to Transfer Pricing

THE ASSTT. COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAY OVERSEAS LTD., JALANDHAR

ITA 49/ASR/2016[2011-12]Status: DisposedITAT Amritsar30 May 2023AY 2011-12

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 10BSection 14A

section 143(1) of the Act at the same income vide order dated 21.03.2009. During the course of assessment proceedings, the Assessing Officer has noticed that International Transactions of the assessee company with its Associate Enterprise during the year under consideration exceeds Rs. 15,00,00,000/- and hence, it required reference to Transfer Pricing

BRODAWAYS OVERSEAS LIMITED,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, JALANDHAR

ITA 123/ASR/2018[2013-14]Status: DisposedITAT Amritsar30 May 2023AY 2013-14

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 10BSection 14A

section 143(1) of the Act at the same income vide order dated 21.03.2009. During the course of assessment proceedings, the Assessing Officer has noticed that International Transactions of the assessee company with its Associate Enterprise during the year under consideration exceeds Rs. 15,00,00,000/- and hence, it required reference to Transfer Pricing

THE ASSTT. COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S BROADWAY OVERSEAS LTD., JALANDHAR

ITA 47/ASR/2016[2009-10]Status: DisposedITAT Amritsar30 May 2023AY 2009-10

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 10BSection 14A

section 143(1) of the Act at the same income vide order dated 21.03.2009. During the course of assessment proceedings, the Assessing Officer has noticed that International Transactions of the assessee company with its Associate Enterprise during the year under consideration exceeds Rs. 15,00,00,000/- and hence, it required reference to Transfer Pricing

M/S CITI PLAZA,JALANDHAR vs. INCOME TAX OFFICER , WARD 3(1), JALANDHAR

In the result, the appeal of the assessee bearing ITA No

ITA 356/ASR/2017[2006-07]Status: DisposedITAT Amritsar13 Sept 2023AY 2006-07

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 147Section 148Section 250

price of Rs.2,30,00,000/-, has wrongly been assessed and upheld in this case. I.T.A. No. 356/Asr/2017 3 Assessment Year: 2006-07 6. That the Id.CIT(A) was not justified in ignoring assessee's submissions that if at all the reopening was valid, the Id ITO could not have given a clean chit to other group of partners headed

SH. MANJIT KRISHAN MALHOTRA,ABOHAR vs. PR. COMMISSIONER OF INCME TAX , BATHINDA

The appeals of the assessee are disposed of in the terms indicated as above

ITA 39/ASR/2019[2008-09]Status: DisposedITAT Amritsar11 Aug 2022AY 2008-09

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Anil Puri, AdvFor Respondent: Sh. Chandrajit Singh, CIT DR
Section 263Section 269SSection 271D

Transfer Pricing Officer" shall have the same meaning as assigned to it in the Explanation to section 92CA.] 2[(2) No order shall be made under sub-section (1

SHRI. MANJIT KRISHAN MALHOTRA,ABOHAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, BATHINDA

The appeals of the assessee are disposed of in the terms indicated as above

ITA 40/ASR/2019[2008-09]Status: DisposedITAT Amritsar11 Aug 2022AY 2008-09

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Anil Puri, AdvFor Respondent: Sh. Chandrajit Singh, CIT DR
Section 263Section 269SSection 271D

Transfer Pricing Officer" shall have the same meaning as assigned to it in the Explanation to section 92CA.] 2[(2) No order shall be made under sub-section (1

M/S. SATIA INDUSTRIES LIMITED,MUKTSAR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1, BATHINDA

In the result, the appeal of the assessee bearing ITA No

ITA 193/ASR/2022[2018-19]Status: DisposedITAT Amritsar13 Jun 2023AY 2018-19

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 115BSection 143(3)Section 144C(8)Section 250oSection 69C

transfer pricing issues in the case of any person having international transactions or in case of a foreign company. It has been provided under sub-section (8) of section 144C that DRP may confirm, reduce or enhance the variations proposed in the draft order of the Assessing Officer. I.T.A. No.193/Asr/2022 36 Assessment Year: 2018-19 In a recent judgement

M/S. JAMMU DEVELOPMENT AUTHORITY,,JAMMU ( J&K) vs. THE DEPUTY COMMISSIONER OF INCOME TAX, JAMMU

In the result, the appeal of the assessee is partly allowed for statistical purposes and the appeal of the department is dismissed

ITA 498/ASR/2013[2005-06]Status: DisposedITAT Amritsar20 Mar 2019AY 2005-06

Bench: Sh. N. S. Saini & Sh. N. K. Choudhryita No. 498/Asr./2013 : Asstt. Year : 2005-06 Jammu Development Authority, Vs Dy. Commissioner Of Income Vikas Bhawan, Rail Head Tax, Circle-I, Complex, Jammu, J & K Jammu (Appellant) (Respondent) Pan No. Aadfj7335A Ita No. 494/Asr./2013 : Asstt. Year : 2005-06 Dy. Commissioner Of Income Vs Jammu Development Authority, Tax, Circle-I, Vikas Bhawan, Rail Head Jammu Complex, Jammu, J & K (Appellant) (Respondent) Pan No. Aabcp1720E Assessee By : Shri. R. K. Gupta, Ca & Shri. Vasu Gupta, Ca Revenue By : Shri. M. P. Singh, Cit Dr Date Of Hearing :21.02.2019 Date Of Pronouncement : 22.03.2019 Order Per N. S. Saini: These Are The Cross Appeals Filed By The Assessee & Revenue Against The Order Of Commissioner Of Income Tax (Appeals) Dated 06.05.2013, Jammu.

For Appellant: Shri. R. K. Gupta, CA &For Respondent: Shri. M. P. Singh, CIT DR

price. Majority of lands under the occupation of JDA have been transferred by the State Govt., without charging any premium. Thus the contention of the assessee that - “It is an agency of Govt., created for development and not for purchase & sale of property. It is further brought to your kind notice that the authority s created have been capitalized

THE DEPUTY COMMISSIONER OF INCOME TAX, JAMMU vs. M/S. JAMMU DEVELPMENT AUTHORITY,, JAMMU

In the result, the appeal of the assessee is partly allowed for statistical purposes and the appeal of the department is dismissed

ITA 494/ASR/2013[2005-06]Status: DisposedITAT Amritsar20 Mar 2019AY 2005-06

Bench: Sh. N. S. Saini & Sh. N. K. Choudhryita No. 498/Asr./2013 : Asstt. Year : 2005-06 Jammu Development Authority, Vs Dy. Commissioner Of Income Vikas Bhawan, Rail Head Tax, Circle-I, Complex, Jammu, J & K Jammu (Appellant) (Respondent) Pan No. Aadfj7335A Ita No. 494/Asr./2013 : Asstt. Year : 2005-06 Dy. Commissioner Of Income Vs Jammu Development Authority, Tax, Circle-I, Vikas Bhawan, Rail Head Jammu Complex, Jammu, J & K (Appellant) (Respondent) Pan No. Aabcp1720E Assessee By : Shri. R. K. Gupta, Ca & Shri. Vasu Gupta, Ca Revenue By : Shri. M. P. Singh, Cit Dr Date Of Hearing :21.02.2019 Date Of Pronouncement : 22.03.2019 Order Per N. S. Saini: These Are The Cross Appeals Filed By The Assessee & Revenue Against The Order Of Commissioner Of Income Tax (Appeals) Dated 06.05.2013, Jammu.

For Appellant: Shri. R. K. Gupta, CA &For Respondent: Shri. M. P. Singh, CIT DR

price. Majority of lands under the occupation of JDA have been transferred by the State Govt., without charging any premium. Thus the contention of the assessee that - “It is an agency of Govt., created for development and not for purchase & sale of property. It is further brought to your kind notice that the authority s created have been capitalized

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

ITA 18/ASR/2017[1987-88]Status: DisposedITAT Amritsar20 Dec 2022AY 1987-88

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 148Section 153(4)

section 153(4) is not applicable in case of the assessee as it is applicable to Transfer Pricing cases referred u/s 92CA. Further the proviso under explanation 1

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

ITA 22/ASR/2017[1991-92]Status: DisposedITAT Amritsar20 Dec 2022AY 1991-92

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 148Section 153(4)

section 153(4) is not applicable in case of the assessee as it is applicable to Transfer Pricing cases referred u/s 92CA. Further the proviso under explanation 1

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

ITA 21/ASR/2017[1990-91]Status: DisposedITAT Amritsar20 Dec 2022AY 1990-91

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 148Section 153(4)

section 153(4) is not applicable in case of the assessee as it is applicable to Transfer Pricing cases referred u/s 92CA. Further the proviso under explanation 1

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

ITA 19/ASR/2017[1988-89]Status: DisposedITAT Amritsar20 Dec 2022AY 1988-89

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 148Section 153(4)

section 153(4) is not applicable in case of the assessee as it is applicable to Transfer Pricing cases referred u/s 92CA. Further the proviso under explanation 1

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

ITA 15/ASR/2017[1984-85]Status: DisposedITAT Amritsar20 Dec 2022AY 1984-85

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 148Section 153(4)

section 153(4) is not applicable in case of the assessee as it is applicable to Transfer Pricing cases referred u/s 92CA. Further the proviso under explanation 1

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

ITA 16/ASR/2017[1985-86]Status: DisposedITAT Amritsar20 Dec 2022AY 1985-86

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 148Section 153(4)

section 153(4) is not applicable in case of the assessee as it is applicable to Transfer Pricing cases referred u/s 92CA. Further the proviso under explanation 1