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21 results for “transfer pricing”+ Section 148(1)clear

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Key Topics

Section 143(3)28Section 153(4)28Section 14824Addition to Income18Section 26310Section 1479Section 80I8Section 808Limitation/Time-bar

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: Disposed

Showing 1–20 of 21 · Page 1 of 2

8
Section 686
Long Term Capital Gains4
Natural Justice3
ITAT Amritsar
13 Jun 2023
AY 2018-19

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

Section 115BSection 143(3)Section 144C(8)Section 250oSection 69C

transfer pricing issues in the case of any person having international transactions or in case of a foreign company. It has been provided under sub-section (8) of section 144C that DRP may confirm, reduce or enhance the variations proposed in the draft order of the Assessing Officer. I.T.A. No.193/Asr/2022 36 Assessment Year: 2018-19 In a recent judgement

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)

148 was issued on 04/08/1994 or later as per chart attached. Further argued that the ld. AR of the assessee has furnished a copy of interim order dated 11/04/1996 in the above writ petitions. In this order of Hon'ble Court, it has been mentioned "Stay to continue'. It appears that stay was granted by the Hon'ble High Court

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 21/ASR/2017[1990-91]Status: DisposedITAT Amritsar20 Dec 2022AY 1990-91

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

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

148 was issued on 04/08/1994 or later as per chart attached. Further argued that the ld. AR of the assessee has furnished a copy of interim order dated 11/04/1996 in the above writ petitions. In this order of Hon'ble Court, it has been mentioned "Stay to continue'. It appears that stay was granted by the Hon'ble High Court

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 19/ASR/2017[1988-89]Status: DisposedITAT Amritsar20 Dec 2022AY 1988-89

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

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

148 was issued on 04/08/1994 or later as per chart attached. Further argued that the ld. AR of the assessee has furnished a copy of interim order dated 11/04/1996 in the above writ petitions. In this order of Hon'ble Court, it has been mentioned "Stay to continue'. It appears that stay was granted by the Hon'ble High Court

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)

148 was issued on 04/08/1994 or later as per chart attached. Further argued that the ld. AR of the assessee has furnished a copy of interim order dated 11/04/1996 in the above writ petitions. In this order of Hon'ble Court, it has been mentioned "Stay to continue'. It appears that stay was granted by the Hon'ble High Court

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 22/ASR/2017[1991-92]Status: DisposedITAT Amritsar20 Dec 2022AY 1991-92

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

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

148 was issued on 04/08/1994 or later as per chart attached. Further argued that the ld. AR of the assessee has furnished a copy of interim order dated 11/04/1996 in the above writ petitions. In this order of Hon'ble Court, it has been mentioned "Stay to continue'. It appears that stay was granted by the Hon'ble High Court

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)

148 was issued on 04/08/1994 or later as per chart attached. Further argued that the ld. AR of the assessee has furnished a copy of interim order dated 11/04/1996 in the above writ petitions. In this order of Hon'ble Court, it has been mentioned "Stay to continue'. It appears that stay was granted by the Hon'ble High Court

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 15/ASR/2017[1984-85]Status: DisposedITAT Amritsar20 Dec 2022AY 1984-85

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

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

148 was issued on 04/08/1994 or later as per chart attached. Further argued that the ld. AR of the assessee has furnished a copy of interim order dated 11/04/1996 in the above writ petitions. In this order of Hon'ble Court, it has been mentioned "Stay to continue'. It appears that stay was granted by the Hon'ble High Court

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

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

148. As the Principal Commissioner agreed with these reasons, it was not necessary for him in his order according sanction to reiterate the reasons furnished by the AO. There is nothing that indicates that he did not apply his mind to the reasons furnished by the AO. 45. Reasons to believe are there. The reasons are based on tangible material

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

SH. GURBACHAN SINGH BRAR,MOGA vs. ITO, WARD - 1,, MOGA

ITA 207/ASR/2017[2010-11]Status: DisposedITAT Amritsar16 Aug 2021AY 2010-11

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

Section 132Section 143(2)Section 153ASection 153CSection 263(1)

price mentioned on the said document. In this AR had submitted that, appellant, during the course of assessment proceedings, 3.7. denied the charge of the Learned Assessing Officer that the said property was actually sold for Rs. 11.25 crores on the following grounds: i) The assessee does not know the source of the purported alleged documents in the possession

SH. SANTOKH SINGH BRAR,MOGA vs. ITO, WARD - 2,, MOGA

ITA 206/ASR/2017[2010-11]Status: DisposedITAT Amritsar16 Aug 2021AY 2010-11

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meena

Section 132Section 143(2)Section 153ASection 153CSection 263(1)

price mentioned on the said document. In this AR had submitted that, appellant, during the course of assessment proceedings, 3.7. denied the charge of the Learned Assessing Officer that the said property was actually sold for Rs. 11.25 crores on the following grounds: i) The assessee does not know the source of the purported alleged documents in the possession

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

148. In response to the notice the Assessee filed Return of Income on 27.04.2019 declaring agricultural income of Rs.1,92,580/- and nil taxable income. 3.1 The Assessing Officer on scrutinising the sale deeds of the land sold by the Assessee noted that the land is mentioned as being agricultural. However, the Assessee had filed complained against the purchaser with

SHRI SURINDER SINGH DECEASED,AMRITSAR. vs. THE INCOME TAX OFFICER,, AMRITSAR.

In the result, the assessee’s appeal is allowed for statistical purposes

ITA 357/ASR/2016[2002-03]Status: DisposedITAT Amritsar30 Jul 2019AY 2002-03

Bench: Sh. Sanjay Arora

For Appellant: Sh. Jatinder Nagpal (Adv.)For Respondent: Sh. S. S. Negi (D.R.)
Section 131(1)Section 143(3)Section 148(1)

148(1) on 26.3.2009, his wife Smt. Jatinder Kaur, filed a reply dated 08.12.2009 (through her counsel, Sh. Nagpal), reproduced at page 3 of the assessment order, stating to be not aware of any such bank account of her late husband and, in any case, of any such money belonging to him, or of any property purchased by, or belonging

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

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

THE ASSTT. COMMISSIONER OF INCOME TAX, JAMMU vs. M/S KAISER INDUSTRIES PVT. LTD, SAMBA

In the result, the appeal of the Revenue is dismissed

ITA 381/ASR/2016[2006-07]Status: DisposedITAT Amritsar20 Mar 2019AY 2006-07

Bench: Sh. N. S. Saini & Sh. N. K. Choudhryita No. 381/Asr./2016 : Asstt. Year : 2006-07 Asstt. Commissioner Of Income Vs M/S Kaiser Industries Pvt. Ltd., Tax, Circle-1, Jammu Industrial Growth Centre, Sidco, Samba (Appellant) (Respondent) Pan No. Aabck0456G Assessee By : Shri. Vasu Gupta, Ca Revenue By : Sh. Yashender Garg, Dr Date Of Hearing :21.02.2019 Date Of Pronouncement : 22.03.2019 Order Per N. S. Saini: This Is An Appeal Filed By The Revenue Against The Order Of Commissioner Of Income Tax (Appeals), Jammu Dated 31.03.2016. 2. The Sole Issue Involved In This Appeal Is That The Commissioner Of Income Tax (Appeals) Erred In Allowing The Deduction U/S 80Ib(4) Of The Income Tax Act, 1961 In Respect Of Samba Unit As The Same Was Claimed To Inflate The Profit Of Eligible Unit For The Motive Of Availing Deduction U/S 80Ib.

For Appellant: Shri. Vasu Gupta, CAFor Respondent: Sh. Yashender Garg, DR
Section 143(3)Section 148Section 80Section 80I

148 of the Act for the reason that a sum of Rs.51,07,624/- on account of Excise duty refund on which deduction u/s 80IB of the Act has been claimed does not qualify for such deduction. The assessment order u/s 143(3)/147 of the Act was passed on 26.03.2013 and the claim of deductions of Rs.2

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

148 and initiation of proceedings under s. 147 were illegal-No substantial question of law arises for consideration" Further reliance is placed on the decision of ITO v/s Lakhmani Mewal Das, Supreme Court, 103 ITR 0437 in which it was held s under: "Reassessment under sec 147(a)-Reason to believe-Must have a material bearing on the question