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27 results for “transfer pricing”+ Section 13(1)(e)clear

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Key Topics

Section 26331Addition to Income25Section 143(3)21Section 10B14Section 6912Section 13211Exemption8Disallowance8Section 14A7

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

Section 92C(1) of the Income Tax Act, 1961, read with Rule 10B of the Income Tax Rules, 1962. The assessee computed the sale value of power at 741,21,19,626, based on a rate of 76.73 per KWH for the total consumption of 6,12,36,200 units (i.e., 76.73 x 6,12,36,200 units). e

Showing 1–20 of 27 · Page 1 of 2

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Section 686
Section 2506

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

e-filed its return of income for the year under consideration on 27.09.2008 declaring therein an income of Rs. 1,58,45,829/- after claiming deduction under section 80IB of the Act at Rs.56,37,834/- on the profits of the Unit-1 (factory premises) of the assessee company situated at G.T. Road, Suranussi, Jalandhar and under section

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

e-filed its return of income for the year under consideration on 27.09.2008 declaring therein an income of Rs. 1,58,45,829/- after claiming deduction under section 80IB of the Act at Rs.56,37,834/- on the profits of the Unit-1 (factory premises) of the assessee company situated at G.T. Road, Suranussi, Jalandhar and under section

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

e-filed its return of income for the year under consideration on 27.09.2008 declaring therein an income of Rs. 1,58,45,829/- after claiming deduction under section 80IB of the Act at Rs.56,37,834/- on the profits of the Unit-1 (factory premises) of the assessee company situated at G.T. Road, Suranussi, Jalandhar and under section

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

e-filed its return of income for the year under consideration on 27.09.2008 declaring therein an income of Rs. 1,58,45,829/- after claiming deduction under section 80IB of the Act at Rs.56,37,834/- on the profits of the Unit-1 (factory premises) of the assessee company situated at G.T. Road, Suranussi, Jalandhar and under section

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

e-filed its return of income for the year under consideration on 27.09.2008 declaring therein an income of Rs. 1,58,45,829/- after claiming deduction under section 80IB of the Act at Rs.56,37,834/- on the profits of the Unit-1 (factory premises) of the assessee company situated at G.T. Road, Suranussi, Jalandhar and under section

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

e-filed its return of income for the year under consideration on 27.09.2008 declaring therein an income of Rs. 1,58,45,829/- after claiming deduction under section 80IB of the Act at Rs.56,37,834/- on the profits of the Unit-1 (factory premises) of the assessee company situated at G.T. Road, Suranussi, Jalandhar and under section

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

e-filed its return of income for the year under consideration on 27.09.2008 declaring therein an income of Rs. 1,58,45,829/- after claiming deduction under section 80IB of the Act at Rs.56,37,834/- on the profits of the Unit-1 (factory premises) of the assessee company situated at G.T. Road, Suranussi, Jalandhar and under section

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

e. It is submitted that in order to encourage the use of renewable sources of energy, such as wind energy, solar energy, steam energy, etc., Ministry of New and Renewable Energy (‘MNRE’) issues transferable and saleable credit certificates under the Electricity Act, 2003, which are generally referred to as “Renewable Energy Certificates (‘RECs’)”. Such RECs are issued, under Central Electricity

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

e) Thereafter, he relied on the assessee’s own case Satia Industries Limited vide ITA No.527/Asr/2024 dated 28.0.2.2025 (placed in page no. 363-383 of PB), for which head notes are reproduced below: TP Adjustment - addition made by AO concerning the variation in the arm's length price of power, where the AO, following the directions of the Dispute Resolution

MAX FINANCIAL SERVICE LIMITED ,NAWANSHAHR vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, JALANDHAR

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

ITA 121/ASR/2020[2015-16]Status: DisposedITAT Amritsar31 Mar 2021AY 2015-16
For Appellant: Shri Deepak ChopraFor Respondent: Smt.Prabhjot Kaur, CIT
Section 143(3)Section 263

1 to section 2(19AA) defining ‘demerger’. As per Explanation 3 to section 2(19AA), ‘undertaking’ shall include any part of an undertaking or a unit or division of an undertaking or a business activity taken as a whole, but does not include individual assets or liabilities or any combination thereof nt constituting a business activity. Explanation 2 to section

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

ITA 306/ASR/2024[2019-20]Status: DisposedITAT Amritsar09 Jan 2025AY 2019-20

Bench: Sh. Vikram Singh Yadav & Sh. Udayan Dasgupta

Section 115BSection 143(3)Section 263Section 263(1)Section 44ASection 69

E) [2022] 145 taxmann.com 590 (Calcutta) HIGH COURT OF CALCUTTA Principal Commissioner of Income-tax v.ReetaLakhmani* Section 10(38), read with section 263, of the Income-tax Act, 1961 - Capital gains - Income arising from transfer of long term securities (Penny stock shares) - Assessment year 2014- 15 - Whether before exercise of power under section 263 it is Principal Commissioner

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

1 & 2 of A-2 DNR which records various payment made to Sh. Surjit Singh and all of these payments have been found recorded in the books of account of the appellant and verified accordingly during remand proceedings by the Assessing Officer. 13. The Assessing Officer has further relied upon documents A-9 DNB-1 which reproduced various ikrarnamas, photo

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

1 & 2 of A-2 DNR which records various payment made to Sh. Surjit Singh and all of these payments have been found recorded in the books of account of the appellant and verified accordingly during remand proceedings by the Assessing Officer. 13. The Assessing Officer has further relied upon documents A-9 DNB-1 which reproduced various ikrarnamas, photo

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

1 & 2 of A-2 DNR which records various payment made to Sh. Surjit Singh and all of these payments have been found recorded in the books of account of the appellant and verified accordingly during remand proceedings by the Assessing Officer. 13. The Assessing Officer has further relied upon documents A-9 DNB-1 which reproduced various ikrarnamas, photo

SMT. INDERMEET BAINS W/O SH. D.S. BAINS,BATHINDA vs. PR. COMMISSIONER OF INCOME TAX , BATHINDA

The appeal of the assessee is disposed of in the term indicated as above

ITA 250/ASR/2019[2011-12]Status: DisposedITAT Amritsar19 Oct 2022AY 2011-12

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

For Appellant: Sh. Sudhir Sehgal & Sh. P.N. Arora, AdvFor Respondent: Sh. Amlendu Nath Misra, CIT DR
Section 143(3)Section 263

section 263 cannot be taken into consideration and the Assessing Officer having taken a plausible view, the assessment as framed by the Assessing Officer cannot be considered to be erroneous and prejudicial to the interest of revenue. 8. Again, the Ld. Counsel, relied upon the judgment of Jurisdictional Bench of ITAT Amritsar Bench, Amritsar in the case of Sh. Jaswinder

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR vs. M/S PUNJAB RICE LAND PRIVATE LIMITED, TARN TARAN

In the result, both the appeals of the revenue are dismissed and

ITA 45/ASR/2021[2014-15]Status: DisposedITAT Amritsar15 Nov 2022AY 2014-15

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

For Appellant: Sh. Jatinder Nagpal, Adv. & Sh. Nimish Nagpal, CAFor Respondent: Sh. Rohit Mehra, CIT DR
Section 132(4)

13: “1. That the Id. CIT(A) has grossly misdirected himself in law and on facts, in upholding the validity of order passed u/s 153A r.w.s 143(3), by not appreciating the assessee's contentions that order is in gross violation of the principles of Natural Justice being passed without confronting the assessee or providing the copies of the statements

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR vs. M/S PUNJAB RICE LAND PRIVATE LIMITED , TARN TARAN

In the result, both the appeals of the revenue are dismissed and

ITA 44/ASR/2021[2012-13]Status: DisposedITAT Amritsar15 Nov 2022AY 2012-13

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

For Appellant: Sh. Jatinder Nagpal, Adv. & Sh. Nimish Nagpal, CAFor Respondent: Sh. Rohit Mehra, CIT DR
Section 132(4)

13: “1. That the Id. CIT(A) has grossly misdirected himself in law and on facts, in upholding the validity of order passed u/s 153A r.w.s 143(3), by not appreciating the assessee's contentions that order is in gross violation of the principles of Natural Justice being passed without confronting the assessee or providing the copies of the statements

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

e-return- AO noticed that there was escapement of income as Assessee had billed royalty under head other income-AO completed assessment u/s. 143(3) restricting TDS-Assessment was reopened to consider relevant TDS relating to income offered by assessee and income included in TDS certificate, which included share of other assessee also -CIT(A) confirmed action of AO-Held

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

e-return- AO noticed that there was escapement of income as Assessee had billed royalty under head other income-AO completed assessment u/s. 143(3) restricting TDS-Assessment was reopened to consider relevant TDS relating to income offered by assessee and income included in TDS certificate, which included share of other assessee also -CIT(A) confirmed action of AO-Held