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22 results for “transfer pricing”+ Section 143(1)(a)clear

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Key Topics

Addition to Income22Section 143(3)19Section 10B14Section 26310Disallowance10Section 1479Section 1489Exemption8Section 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

1. That on the facts and circumstances of the case, the order passed by the AO under section 143(3) read with section 144C(13) in consequence of directions of DRP u/s l44C(5) section 144C(13) in consequence of directions of DRP u/sl44C(5) of the Income Tax Act,1961 in reducing the deduction claimed by the assessee

Showing 1–20 of 22 · Page 1 of 2

Section 1327
Section 2506
Survey u/s 133A4

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 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

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 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

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

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

143(3) r.w.s. 144C dated 26.07.2022, in pursuance of directions of Dispute Resolution Panel dated 29.06.2022, and the amount of Rs. 4,57,32,318/- paid to ZYLO international has been wrongly treated as bogus expenditure u/s 69C and further the amount of Rs. 17,77,26,000/- received on account of sale/ transfer of Recs/ESCs has been wrongly treated

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

1. That on the facts and circumstances of the case, the AD erred in making addition of Rs. 8,85,40,036/- vide order under section 143(3) read with section 144C(13) in consequence of directions of DRP u/s144C(5) of the Income Tax Act, 1961. 2. That the Assessing Officer (AO) has erred in making an addition

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

143(1) Subsequently, Principal\nCommissioner invoked revision under section 263 on ground that a land was sold by\nassessee to an entity below value adopted by concerned authority for levy of stamp duty,\nand therefore, there was under-assessment of income to extent of differential amount, and\naccordingly, assessment made was contrary to provisions of section 50C as this aspect

NASA AGRO INDUSTRIES PRIVATE LIMITED,FAZILKA vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-II, BATHINDA

In the result, the appeal filed by the assessee is allowed for statistical purpose

ITA 236/ASR/2023[2011-12]Status: DisposedITAT Amritsar26 Sept 2025AY 2011-12

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

For Appellant: Sh. Y. K. Sud & Sh. P. K. Anand, CAs
Section 132Section 142(1)Section 143(3)Section 148Section 153cSection 250

transferred by the assessee to the M/s Devinder Kumar Deepesh Kumar ,as an accommodation entry for recording of bogus purchase, because 4 I.T.A. No. 236/Asr/2023 Assessment Year: 2011-12 as per the AO the physical movement of goods could not be proved, in absence of any Bilty, weighment slip of goods, octroi receipts, and in absence of any proof

INCOME TAX OFFICER WARD-2 (2), MUKTSAR vs. AJAIB SINGH, VILLAGE BHARU

In the result, the appeal of the revenue is dismissed

ITA 354/ASR/2024[2012]Status: DisposedITAT Amritsar30 Jun 2025

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay(Hybrid Hearing) I.T.A. No. 354/Asr/2024 Assessment Year: 2012-13

Section 143(3)Section 2(14)(iii)Section 250Section 54B

143(3) r.w.s. 147 dated 28.12.2019 assessing the Long Term Capital Gain at Rs.3,68,15,000/-. Aggrieved by the said order the Assessee has instituted the current appeal.” I.T.A. No. 354/Asr/2024 6 Assessment Year: 2012-13 5. Thereafter, in para no. 5.1 in appellate order the ld. CIT(A) has observed as follows: “5.1 1 As per Section

SHRI NITIN AIMA,SHRINAGAR vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3, SRINAGAR

The appeal of the assessee is dismissed

ITA 83/ASR/2020[2015-16]Status: DisposedITAT Amritsar27 Feb 2025AY 2015-16
Section 10ASection 143(3)Section 250Section 37Section 75Section 80

143(3) of the Act dated 27.12.2017 for A.Y. 2015-\n16.\n2.\nThe grounds of appeal preferred by the assessee as per memorandum of\nappeal are as under;\n1. That the learned CIT(A) has erred in not defeating the\naddition made on account of export incentives of the assesse\nwhich is exempt under section 10AA

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

143(2) on 12.11.2014 served upon the assessee on 5 I.T.A. No. 90/Asr/2017 Blue City Township & Colonizers v. ITO 13.11.2014 fixing the case for hearing on 20.11.2014. The case of the appellant company was adjourned on different dates at the request of the ld. counsel for the assessee company during the course of assessment proceedings by granting adjournment

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

143 of the Income-tax Act, 1961 [Corresponding to section 23(3) of the Indian Income-tax Act, 1922]-Assessment - Additions to income - Assessment year 1944-45-Whether though ITO is not fettered by technical rules of evidence and pleadings and he is entitled to act on material which may not be accepted as evidence on account

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

143(2) was issued to the appellant by the AO. Various notices u/s 142(1) was also issued to the appellant along with the detailed questionnaire. But no response was filed in response to the notices w/s 142(1) and therefore, the appellant was issued summons us 131 for personal appearance on 14.11.2019 along with bank account and detailed capital

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)

transferred to the following concerns during the year itself on various dates- S.S. Enterprises, JalalabadRs.3,62,93,300/- Narinder Joson& Co., JalalabadRs.6,11,56,000/- Amrinder& Sons, Jalalabad Rs. 2,00,00,000/- Gurkirat Enterprises, Jalalabad Rs. 2,00,00,000/- Nawab Trading Rs. 1,07,06,700/- Josan Food Pvt. Ltd., Rs. 2,00,00,000/-” The ld. Counsel

SHRI JASBIR SINGH ,AMRITSAR vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR

In the result, appeal of the assesseeITA No

ITA 133/ASR/2022[2019-20]Status: DisposedITAT Amritsar07 Aug 2023AY 2019-20

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No. 133/Asr/2022 Assessment Year: 2019-20

Section 143(3)Section 250Section 69

143(3) of the Act. I.T.A. No. 133/Asr/2022 2 Assessment Year: 2019-20 2. The assessee has taken the following grounds: “1. That the order of the Learned ACI1 making additions and likewise Ld. CIT(A) confirming the same is wrong, illegal and against facts. 2. That the Ld. AO erred under law and facts in making addition