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43 results for “transfer pricing”+ Section 143(3)clear

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Key Topics

Section 143(3)53Section 26347Addition to Income36Section 153(4)28Section 14824Section 10B14Section 8014Disallowance12Section 14711Section 80I

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 Officer (in short ‘TPO’) dated 5.12.2021 for A.Y. 2020-21. 2. Brief facts of the case, as per the order/directions of the Dispute Resolution Panel-1, New Delhi [herein referred to as ‘DRP’ ] dated 24.06.2024 for A.Y. 2020-21 are as under:- “Profile of the Assessee: Satia Industries Limited (hereinafter referred as 'the Assessee

Showing 1–20 of 43 · Page 1 of 3

11
Exemption8
Limitation/Time-bar8

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

143(3)/263 on following issues: " Issue of claim of exemption of Rs. 5,12,75,000 as exempt capital gain on sale of agriculture land " Issue of nature of land on which capital gain has been claim exempt and evidence of agricultural activity carried on such land " Issue of source of purchase of land under consideration way back

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

Transfer Pricing Officer could not have taken cognizance suo moto of any international transaction for adjustment in the arm's length price u/s 92CA of the Income Tax Act, 1961 because no reference was made for the aforesaid transaction 9 I.T.A. Nos. 477 & CO 32/Asr/2015 & Ors Asstt. CIT v. Broadways Overseas Ltd. & Ors 4. That the appellant craves leave

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

Transfer Pricing Officer could not have taken cognizance suo moto of any international transaction for adjustment in the arm's length price u/s 92CA of the Income Tax Act, 1961 because no reference was made for the aforesaid transaction 9 I.T.A. Nos. 477 & CO 32/Asr/2015 & Ors Asstt. CIT v. Broadways Overseas Ltd. & Ors 4. That the appellant craves leave

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

Transfer Pricing Officer could not have taken cognizance suo moto of any international transaction for adjustment in the arm's length price u/s 92CA of the Income Tax Act, 1961 because no reference was made for the aforesaid transaction 9 I.T.A. Nos. 477 & CO 32/Asr/2015 & Ors Asstt. CIT v. Broadways Overseas Ltd. & Ors 4. That the appellant craves leave

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

Transfer Pricing Officer could not have taken cognizance suo moto of any international transaction for adjustment in the arm's length price u/s 92CA of the Income Tax Act, 1961 because no reference was made for the aforesaid transaction 9 I.T.A. Nos. 477 & CO 32/Asr/2015 & Ors Asstt. CIT v. Broadways Overseas Ltd. & Ors 4. That the appellant craves leave

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

Transfer Pricing Officer could not have taken cognizance suo moto of any international transaction for adjustment in the arm's length price u/s 92CA of the Income Tax Act, 1961 because no reference was made for the aforesaid transaction 9 I.T.A. Nos. 477 & CO 32/Asr/2015 & Ors Asstt. CIT v. Broadways Overseas Ltd. & Ors 4. That the appellant craves leave

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

Transfer Pricing Officer could not have taken cognizance suo moto of any international transaction for adjustment in the arm's length price u/s 92CA of the Income Tax Act, 1961 because no reference was made for the aforesaid transaction 9 I.T.A. Nos. 477 & CO 32/Asr/2015 & Ors Asstt. CIT v. Broadways Overseas Ltd. & Ors 4. That the appellant craves leave

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

Transfer Pricing Officer could not have taken cognizance suo moto of any international transaction for adjustment in the arm's length price u/s 92CA of the Income Tax Act, 1961 because no reference was made for the aforesaid transaction 9 I.T.A. Nos. 477 & CO 32/Asr/2015 & Ors Asstt. CIT v. Broadways Overseas Ltd. & Ors 4. That the appellant craves leave

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

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

3), 147, 273B Case pertains to Asst. Year1961-62, 1962-63, 1963-64, 1964-65 Decision in favour of: Assessee SUHAS CHANDRA SEN J 24. It was ultimately held by Chandurkar J. that : "The words 'regular assessment' which were to be found in sub-s. (9) of s. 18A of the Indian IT Act, 1922, have, no doubt, been construed

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

3), 147, 273B Case pertains to Asst. Year1961-62, 1962-63, 1963-64, 1964-65 Decision in favour of: Assessee SUHAS CHANDRA SEN J 24. It was ultimately held by Chandurkar J. that : "The words 'regular assessment' which were to be found in sub-s. (9) of s. 18A of the Indian IT Act, 1922, have, no doubt, been construed

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)

section 151 of the Act." Notice u/s 148 of the I.T.Act,1961 was issued on 30.03.2018 and served on assessee on 30.03.2018. In response to the notice u/s 148, assessee e-filed his return on 26.12.2018 at a income of Rs. 77,66,950/-. Notice u/s 143(2) was issued on 15.10.2018, fixing the case for hearing

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)

section 151 of the Act." Notice u/s 148 of the I.T.Act,1961 was issued on 30.03.2018 and served on assessee on 30.03.2018. In response to the notice u/s 148, assessee e-filed his return on 26.12.2018 at a income of Rs. 77,66,950/-. Notice u/s 143(2) was issued on 15.10.2018, fixing the case for hearing

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

143(3) r.w.s. 144C(13)/144B of the income tax Act 61 (hereinafter the Act 61) dated 25/10/2024, in respect of which reference was made to TPO for determination of ALP u/s 92CA (after 2 I.T.A. No. 702/Asr/2024 Assessment Year: 2021-22 necessary approval from PCIT), and assessment completed , considering transfer pricing adjustments ,vide order u/s 92CA(3) dated 30/10/2023

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

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

143(3) of the Act was erroneous or prejudicial to the interest of revenue. 4. That the assumption of jurisdiction under section 263 is also bad in law since the PCIT has failed to demonstrate as to how any of the conditions prescribed in Explanation 2 to section action 263 of the Act stood satisfied on the facts

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)

143(3)/147 on dated 21.03.2014, which had violated the limitation u/s 153(4) of the Act. As per the ld. counsel the order should be passed by the ld. AO within the 60 days after receiving the order of the Hon’ble High I.T.A. Nos. 15 to 22/Asr/2017 4 A.Ys.: 1984-85 to 1991-92 Court and the assessing

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 17/ASR/2017[1986-87]Status: DisposedITAT Amritsar20 Dec 2022AY 1986-87

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

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

143(3)/147 on dated 21.03.2014, which had violated the limitation u/s 153(4) of the Act. As per the ld. counsel the order should be passed by the ld. AO within the 60 days after receiving the order of the Hon’ble High I.T.A. Nos. 15 to 22/Asr/2017 4 A.Ys.: 1984-85 to 1991-92 Court and the assessing

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)

143(3)/147 on dated 21.03.2014, which had violated the limitation u/s 153(4) of the Act. As per the ld. counsel the order should be passed by the ld. AO within the 60 days after receiving the order of the Hon’ble High I.T.A. Nos. 15 to 22/Asr/2017 4 A.Ys.: 1984-85 to 1991-92 Court and the assessing