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5 results for “transfer pricing”+ Section 120(4)(b)clear

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Key Topics

Section 26316Section 271D8Section 269S6Section 143(3)3Addition to Income3Section 1482Section 144C(13)2Section 802Penalty2

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

4)(iv) of the Income Tax Act, 1961, in respect of Co- generation Unit 1, specifically for the supply of electricity and steam to its non-specified unit, the Paper Unit. 5.3 The assessee has adopted the Transaction Net Margin Method (TNMM) for determining the arm's length price for the transfer of power from the specified Co-generation Unit

Condonation of Delay2

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

4. The intricate legal issue relating to lack of jurisdiction vested in Pr.Commissioner of Income Tax under section 263 was not there in the knowledge of the petitioner appellant as well as his regular counsel Mr. Mahesh Chander Khungar, resulting need for filing of appeal against impugned order dated 29.03.2016 never cropped up in their mind, inter-alia no appeal

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

4. The intricate legal issue relating to lack of jurisdiction vested in Pr.Commissioner of Income Tax under section 263 was not there in the knowledge of the petitioner appellant as well as his regular counsel Mr. Mahesh Chander Khungar, resulting need for filing of appeal against impugned order dated 29.03.2016 never cropped up in their mind, inter-alia no appeal

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

120 ITR 14 (SC), heavily relied upon by assessee, holding that 'when it is left to the option or discretion of the ITO, whether or not to take an action, it cannot be described as direction". Various other binding judicial decisions relied upon by assessee, but not considered by the ld.CIT(A), also render his order as unsustainable. 3. That

MESERS GANESH RICE MILLS,MUKTSAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-II, BATHINDA

In the result the appeal of the assessee ITA No

ITA 287/ASR/2018[2014-15]Status: DisposedITAT Amritsar15 Feb 2023AY 2014-15

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

For Appellant: Sh. Sudhir Sehgal, A. RFor Respondent: Sh. Rohit Mehra, CIT DR
Section 133ASection 143(3)Section 250(6)

120/- i.e after making an addition of Rs. 15,65,41,118/-by rejecting the audited books of accounts of the assessee. Appeal was filed before the ld. CIT(A) against the order of the AO. The ld. CIT(A) partly allowed the appeal. The addition was restricted amount to Rs. 15,54,20,000/- against the assessee. Being dissatisfied