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23 results for “transfer pricing”+ Section 10(34)clear

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Key Topics

Addition to Income23Section 143(3)17Section 10B14Section 6913Section 26310Section 1479Section 1489Disallowance9Exemption8

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

34 difference of Rs. 1,95,80,958. The assessee had adopted the Transactional Net Margin Method (TNMM), while the Dispute Resolution Panel (DRP) considered the Cost-Pius Method (CPM) as the most appropriate method (MAM), solely pointing out that steam is not transferred. The AR contended that the steam captively consumed was marketable and drew attention

Showing 1–20 of 23 · Page 1 of 2

Section 14A7
Section 1327
Long Term Capital Gains4

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

10 and 10B of the Act. It appears that the object of s. 80A(4) was to ensure that a unit which has availed of the benefit under s. 10B will not be allowed to further claim relief under s. 80-IA or 80-IB r/w s. 80A(4). The intention does not appear to be to deny relief under

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

10 and 10B of the Act. It appears that the object of s. 80A(4) was to ensure that a unit which has availed of the benefit under s. 10B will not be allowed to further claim relief under s. 80-IA or 80-IB r/w s. 80A(4). The intention does not appear to be to deny relief under

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

10 and 10B of the Act. It appears that the object of s. 80A(4) was to ensure that a unit which has availed of the benefit under s. 10B will not be allowed to further claim relief under s. 80-IA or 80-IB r/w s. 80A(4). The intention does not appear to be to deny relief under

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

10 and 10B of the Act. It appears that the object of s. 80A(4) was to ensure that a unit which has availed of the benefit under s. 10B will not be allowed to further claim relief under s. 80-IA or 80-IB r/w s. 80A(4). The intention does not appear to be to deny relief under

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

10 and 10B of the Act. It appears that the object of s. 80A(4) was to ensure that a unit which has availed of the benefit under s. 10B will not be allowed to further claim relief under s. 80-IA or 80-IB r/w s. 80A(4). The intention does not appear to be to deny relief under

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

10 and 10B of the Act. It appears that the object of s. 80A(4) was to ensure that a unit which has availed of the benefit under s. 10B will not be allowed to further claim relief under s. 80-IA or 80-IB r/w s. 80A(4). The intention does not appear to be to deny relief under

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

10 and 10B of the Act. It appears that the object of s. 80A(4) was to ensure that a unit which has availed of the benefit under s. 10B will not be allowed to further claim relief under s. 80-IA or 80-IB r/w s. 80A(4). The intention does not appear to be to deny relief under

SMT. SATYAWATI MARWAHA THROUGH LEGAL HEIR SH. CHANDER SHEIKHAR MARWAHA,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeal for Asstt

ITA 346/ASR/2024[2014-15]Status: DisposedITAT Amritsar30 Oct 2025AY 2014-15

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Ashray Sarna, C. A
Section 10(38)Section 132Section 144Section 144rSection 147Section 148Section 151Section 250(6)Section 68

transfer of long term securities (Share dealings) - Assessment year 2013-14 - Assessee had sold shares of SNCFL and earned long-term capital gains - Assessing Officer issued a show cause notice alleging that transaction was a pennystock deal aimed at illegitimately claiming long-term capital gain exemption under section 10(38) - Assessing Officer treated purchase as bogus and added

SMT. SATYAWATI MARWAHA THROUGH LEGAL HEIR SH, CHANDER SHEIKHAR MARWAHA,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeal for Asstt

ITA 347/ASR/2024[2015-16]Status: DisposedITAT Amritsar30 Oct 2025AY 2015-16

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Ashray Sarna, C. A
Section 10(38)Section 132Section 144Section 144rSection 147Section 148Section 151Section 250(6)Section 68

transfer of long term securities (Share dealings) - Assessment year 2013-14 - Assessee had sold shares of SNCFL and earned long-term capital gains - Assessing Officer issued a show cause notice alleging that transaction was a pennystock deal aimed at illegitimately claiming long-term capital gain exemption under section 10(38) - Assessing Officer treated purchase as bogus and added

SATIA INDUSTRIES LIMITED,MUKTSAR vs. DCIT/ACIT CIRCLE I, BATHINDA, BATHINDA

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

ITA 702/ASR/2024[2021-22]Status: DisposedITAT Amritsar16 Dec 2025AY 2021-22

Bench: Dr. M. L. Meena & Sh. Udayan Dasgupta

For Appellant: Sh. Rohit Kapoor, Adv. &
Section 143(3)Section 144C(1)Section 144C(2)Section 144C(5)Section 80Section 80GSection 80ISection 92C

section 80G of Income Tax Act 1961. 9. That the Appellant craves leave to add or amend the grounds of appeal before the appeal is finally heard or disposed of.” 10. In course of hearing of the appeal, the assessee has filed a written submissions on all the grounds contained in the memorandum and has based his arguments

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

ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE), JAMMU vs. ANITA KAPAHI, JAMMU

In the result, the appeal of the revenue is dismissed being devoid of merits

ITA 557/ASR/2024[2019-20]Status: DisposedITAT Amritsar29 May 2025AY 2019-20

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay

For Appellant: Sh. P. N. Arora, Adv
Section 131Section 132Section 133ASection 143(3)Section 250(6)Section 69

34 ITR 328 (Mad.) has held as under: "During relevant assessment year assessee exported and also sold onions in open market at controlled price However ITO taking view that assessee must have sold goods in open market at price higher than controlled price made certain addition in assessee's income - In coming to said conclusion, ITO relied upon transactions entered

THE DY. COMMISSIONER INCOME-TAX, JAMMU vs. M/S. HORIZON BUILDCON PVT. LTD,, JAMMU

In the result, the appeals of the Revenue in I

ITA 673/ASR/2014[2011-12]Status: DisposedITAT Amritsar22 Mar 2023AY 2011-12

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

For Appellant: Sh. Hitendra Bhauraoji Ninawe, CIT DRFor Respondent: S/Sh. P.N. Arora, Adv., Pradeep
Section 69

34 kanals out of about 88 kanals piece of land for which per sq yard rate is hovering around Rs. 3900 per sq. yard, even though said piece of land for which price as per ikrarnamas is only 1400 per sq. yard in the same khasra. The detailed analysis with reference to the AR's contention on the issue

THE DY. COMMISSIONER INCOME-TAX, JAMMU vs. M/S. HORIZON BUILDCON PVT. LTD,, JAMMU

In the result, the appeals of the Revenue in I

ITA 671/ASR/2014[2009-10]Status: DisposedITAT Amritsar22 Mar 2023AY 2009-10

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

For Appellant: Sh. Hitendra Bhauraoji Ninawe, CIT DRFor Respondent: S/Sh. P.N. Arora, Adv., Pradeep
Section 69

34 kanals out of about 88 kanals piece of land for which per sq yard rate is hovering around Rs. 3900 per sq. yard, even though said piece of land for which price as per ikrarnamas is only 1400 per sq. yard in the same khasra. The detailed analysis with reference to the AR's contention on the issue

THE DY. COMMISSIONER INCOME-TAX, JAMMU vs. M/S. HORIZON BUILDCON PVT. LTD,, JAMMU

In the result, the appeals of the Revenue in I

ITA 672/ASR/2014[201-11]Status: DisposedITAT Amritsar22 Mar 2023

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

For Appellant: Sh. Hitendra Bhauraoji Ninawe, CIT DRFor Respondent: S/Sh. P.N. Arora, Adv., Pradeep
Section 69

34 kanals out of about 88 kanals piece of land for which per sq yard rate is hovering around Rs. 3900 per sq. yard, even though said piece of land for which price as per ikrarnamas is only 1400 per sq. yard in the same khasra. The detailed analysis with reference to the AR's contention on the issue

POONAM MARWAHA,AMRITSAR vs. ACIT DCIT CEN CIR, AMRITSAR

In the result, the appeal filed by assessee is allowed

ITA 306/ASR/2024[2019-20]Status: DisposedITAT Amritsar09 Jan 2025AY 2019-20
Section 115BSection 143(3)Section 263Section 263(1)Section 69

transfer of long term securities (Penny stock shares) - Assessment year 2014-\n15 - Whether before exercise of power under section 263 it is Principal Commissioner\nwho has to apply its mind to issue and thereafter record reasons as to how twin conditions\nof order of Assessing Officer being erroneous and prejudicial to interest of revenue are\nsatisfied and then issue

M/S BLUE CITY TOWNSHIP & COLONIZERS,AMRITSAR. vs. THE INCOME TAX OFFICER,, AMRITSAR.

ITA 90/ASR/2017[2009-10]Status: DisposedITAT Amritsar14 Jul 2023AY 2009-10

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

Section 147Section 148Section 151Section 234ASection 69

section 68. 20. Per contra, the Ld. DR supported the impugned order. He contended that the AO observed that the amounts which the assessee paid over and above the prices mentioned in the registries of purchase of land by the assessee company during FY 2008-09 were amounting to a sum of Rs 216,23,000/-, being the cash deposited

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

Section 139 (5) of the Act was filed before the Assessing Officer. We answer both the question Nos. 1 and 2 in negative and in favour of assessee”. Ground No. 3 9. Ground No. 3, not pressed. Ground Nos. 4 & 5 I.T.A. No.193/Asr/2022 32 Assessment Year: 2018-19 10. The ld. AR argued that the assessee paidcommission during financial year

INCOME TAX OFFICER, INCOME TAX OFFICE vs. VIKAS MEHRA, THE MALL

In the result, the appeal filed by the revenue is dismissed being devoid of

ITA 287/ASR/2023[2017-18]Status: DisposedITAT Amritsar07 Aug 2025AY 2017-18

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Jatinder Nagpal, Adv
Section 143(3)Section 250Section 49

price index on purchase value, indexed cost comes to Rs 8.800/- and Rs.792,000/- respectively. But the appellant credited his account with amount of Rs.2.55,00,000/- instead of Rs 8,00,800/- without paying any tax Therefore the appellant was given final opportunity to explain as to why the amount