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26 results for “transfer pricing”+ Section 17(1)clear

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Key Topics

Addition to Income26Section 143(3)16Section 10B14Section 13213Section 25010Section 26310Disallowance10Section 1479Section 1489

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 26 · Page 1 of 2

Exemption8
Section 14A7
Search & Seizure7

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

1,48,40,164/- made by the Assessing Officer to the income of the assessee company by way of Arms Length Price adjustments in respect of interest on loan in foreign currency is directed to be deleted. 10.5 As far as the other adjustment in respect of excess period credit in respect of receivables is concerned, the TPO after treating

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

1,48,40,164/- made by the Assessing Officer to the income of the assessee company by way of Arms Length Price adjustments in respect of interest on loan in foreign currency is directed to be deleted. 10.5 As far as the other adjustment in respect of excess period credit in respect of receivables is concerned, the TPO after treating

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

1,48,40,164/- made by the Assessing Officer to the income of the assessee company by way of Arms Length Price adjustments in respect of interest on loan in foreign currency is directed to be deleted. 10.5 As far as the other adjustment in respect of excess period credit in respect of receivables is concerned, the TPO after treating

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

1,48,40,164/- made by the Assessing Officer to the income of the assessee company by way of Arms Length Price adjustments in respect of interest on loan in foreign currency is directed to be deleted. 10.5 As far as the other adjustment in respect of excess period credit in respect of receivables is concerned, the TPO after treating

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

1,48,40,164/- made by the Assessing Officer to the income of the assessee company by way of Arms Length Price adjustments in respect of interest on loan in foreign currency is directed to be deleted. 10.5 As far as the other adjustment in respect of excess period credit in respect of receivables is concerned, the TPO after treating

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

1,48,40,164/- made by the Assessing Officer to the income of the assessee company by way of Arms Length Price adjustments in respect of interest on loan in foreign currency is directed to be deleted. 10.5 As far as the other adjustment in respect of excess period credit in respect of receivables is concerned, the TPO after treating

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

1,48,40,164/- made by the Assessing Officer to the income of the assessee company by way of Arms Length Price adjustments in respect of interest on loan in foreign currency is directed to be deleted. 10.5 As far as the other adjustment in respect of excess period credit in respect of receivables is concerned, the TPO after treating

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

1). Explanation, -For the purposes of this section ’carbon credit" in respect of one unit shall mean reduction of one tonne of carbon dioxide emissions or emissions of its equivalent gases which is validated by die United Nations Framework on Climate Change and which can be traded In market at its prevailing market price. Thus, the Panel

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

17 I.T.A. No. 702/Asr/2024 Assessment Year: 2021-22 I. Section 80-IA of the Income-tax Act, 1961 read with section 43A of the Electricity (Supply) Act, 1948 - Deductions - Profits and gains from infrastructure undertakings (Computation of deduction) - Assessment year 2001-02 - Assessee, engaged in electricity generation and industrial activities, established captive power plants due to insufficient supply from State

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

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

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

17. The next question is-what is duty draw back?. Section 75 of the\nCustoms Act, 1962 and section 37 of the Central Excise Act, 1944\nempower Government of India to provide for the payment of customs\nand excise duty paid by an assessee. The refund is of the average\namount of duty paid on materials of any particular class

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

1. Whether upon facts and circumstances of the case and in law, the Ld. CIT(A) was justified in deleting the addition of Rs. 2,05,44,000/- made by the assessing officer ignoring the contradiction in the statements of assessee and seller with regard to the seized document at annexure A3 page 66 impounded during the course of search

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

17 I.T.A. No. 90/Asr/2017 Blue City Township & Colonizers v. ITO Name S B A/c No. Sh Baldev Singh 81002010052180 Sh Gursharn Singh 81002200011499 Sh Gurmukh Singh 8100220011484 Sh Malook Singh 81002200011470 The perusal of account statement of Sh Baldev Singh revealed the credit of Rs 1 Crore on 04-04-2008 by transfer. Likewise, the account of Sh Malook Singh

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

1) and therefore, the appellant was issued summons us 131 for personal appearance on 14.11.2019 along with bank account and detailed capital account explaining the increase in large share capital during the year. In response Sh. Jatinder Nagpal, Advocate filed online reply along with capital account, copy of registered deed in respect of immovable property and documentary evidence relating

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1, JALANDHAR vs. SHRI JATINDER SINGH BEDI , JALANDHAR

In the result, the appeal of the revenue, ITA No 90/Asr/2020 is dismissed

ITA 90/ASR/2020[2017-18]Status: DisposedITAT Amritsar11 Apr 2023AY 2017-18

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

Section 132Section 139Section 153ASection 250Section 69A

transferred and registration of 3 Kanal 10 Marla was executed on 18.05.2018 for Rs.42 lacs and the balance property including the building & others are still in possession & power of M/s. S. Amar Singh Educational Charitable Trust. The electricity bill of the institute is still in the name of GNA-IMT which, as per the AR, justifies the claims

SHRI BHAVNOOR SINGH BEDI,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, JALANDHAR

In the result, the appeal of the revenue, ITA No 90/Asr/2020 is dismissed

ITA 51/ASR/2020[2014-15]Status: DisposedITAT Amritsar11 Apr 2023AY 2014-15

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

Section 132Section 139Section 153ASection 250Section 69A

transferred and registration of 3 Kanal 10 Marla was executed on 18.05.2018 for Rs.42 lacs and the balance property including the building & others are still in possession & power of M/s. S. Amar Singh Educational Charitable Trust. The electricity bill of the institute is still in the name of GNA-IMT which, as per the AR, justifies the claims

SHRI BHAVNOOR SINGH BEDI,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, JALANDHAR

In the result, the appeal of the revenue, ITA No 90/Asr/2020 is dismissed

ITA 53/ASR/2020[2016-17]Status: DisposedITAT Amritsar11 Apr 2023AY 2016-17

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

Section 132Section 139Section 153ASection 250Section 69A

transferred and registration of 3 Kanal 10 Marla was executed on 18.05.2018 for Rs.42 lacs and the balance property including the building & others are still in possession & power of M/s. S. Amar Singh Educational Charitable Trust. The electricity bill of the institute is still in the name of GNA-IMT which, as per the AR, justifies the claims