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

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Key Topics

Section 26331Section 143(3)26Addition to Income12Section 1327Section 1476Section 686Section 153C6Section 695Section 250(6)4

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

iv) of the Income Tax Act, 1961, in respect of Co- generation Unit 1, specifically for the supply of electricity and steam to its non-specified unit, the Paper Unit. 5.3 The assessee has adopted the Transaction Net Margin Method (TNMM) for determining the arm's length price for the transfer of power from the specified Co-generation Unit

Unexplained Money4
Business Income3
Natural Justice3

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

17 taxmann.com 186 (Orissa)- Held“Section 139 of the Income-tax Act, 1961 - Return of income - Revised return - Assessment year 2006-07 - Whether an assessee can revise his return of income by way of filing a revised statement of income after filing original return other than by way of filing revised return as contemplated under section 139(5) - Held

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

iv) of the Act 61 in respect of the power and steam generated by UNIT -1, (functioning with a capacity of 12.5 Mega Watt), and the electricity and steam so generated being transferred to the paper manufacturing unit (non-specified unit) has adopted TNMM (transactional net margin method), as a comparison for working out net profit margins earned by independent

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

17 A.Y.2015-16 find are totally different. In the present case the rental income was earned on letting out residential property to the key managerial personnel of the assessee company in lieu of its retention policy. This fact has remained uncontroverted by the Ld.Pr.CIT and even before us. Based on identical set of facts, various judicial decisions, as referred

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

1 of brief synopsis. 2. [2015] 60 taxmann.com (Kolkata - Trib.) IN THE ITAT KOLKATA BENCH 'B' Subhlakshmi Vanijya (P.) Ltd. Commissioner Income-tax-I, Kolkata V. of 60 Section 68, read with section 263, of the Income-tax Act, 1961 - Cash credit (Share capital) Assessment years 2008-09 to 2010-11 - Assessee filed return offering meagre income and issued share

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

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

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

price of impugned land purchase, ignoring the detailed discussion of the same in the assessment order; that the Ld. CIT(A) is not right to 15 I.T.A. No.557/Asr/2024 Assessment Year: 2019-20 hold that various ikrarnamas, photocopies of which were found and seized during search viz. A-9 DNB-1 are collusive in nature, as claimed by the assessee, when

SMT. GURJEET KAUR,JALANDHAR vs. INCOME TAX OFFICER, WARD- IV (2),, JALANDHAR

The appeal of the assessee is allowed in terms of our

ITA 628/ASR/2017[2009-10]Status: DisposedITAT Amritsar21 Feb 2022AY 2009-10

Bench: Sh. Ravish Sood & Dr. M. L. Meena

For Appellant: Sh. Surinder Mahajan, CAFor Respondent: Sh. Sunil Gautam, CIT-DR
Section 143(3)Section 147Section 69Section 91

transferred from his bank account. Backed by his aforesaid observations, the A.O acting upon the contents of the “agreement to sell”, therein, held the amount of Rs. 1.50 crore received by the assessee as 8 Smt. Gurjeet Kaur Vs. ITO-Ward 3(4), Jalandhar ITA No. 627 & 628/Asr/2017 – A.Y 2008-09 & 2009-10 earnest money from Sh. Surjit Singh (supra

SMT. GURJEET KAUR,JALANDHAR vs. INCOME TAX OFFICER, WARD- IV (2),, JALANDHAR

The appeal of the assessee is allowed in terms of our

ITA 627/ASR/2017[2008-09]Status: DisposedITAT Amritsar21 Feb 2022AY 2008-09

Bench: Sh. Ravish Sood & Dr. M. L. Meena

For Appellant: Sh. Surinder Mahajan, CAFor Respondent: Sh. Sunil Gautam, CIT-DR
Section 143(3)Section 147Section 69Section 91

transferred from his bank account. Backed by his aforesaid observations, the A.O acting upon the contents of the “agreement to sell”, therein, held the amount of Rs. 1.50 crore received by the assessee as 8 Smt. Gurjeet Kaur Vs. ITO-Ward 3(4), Jalandhar ITA No. 627 & 628/Asr/2017 – A.Y 2008-09 & 2009-10 earnest money from Sh. Surjit Singh (supra

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

iv). Copy of the judgment of ITAT, Chandigarh Bench, Chandigarh in the case of Surinder Kaur in ITA No. 86/Chd/2021 vide order dated 06.05.2022 on the issue of u/s 263. v). Loil Continental Foods Ltd. vs. Pr. CIT in ITA No. 577/Chd/2019 Chd-Trib. vi). CIT vs. Hindustan Marketing & Advertising Co. Ltd. 341 ITR 180 Delhi-HC vii). Commissioner

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

1, Jalandhar, dated 29/03/2022, where the abovementioned bank account of the assessee held with “ Capital Small Finance Bank” has been examined and some additions has been made on account of unexplained credit entries in such bank , but there is no adverse findings in respect of the investment of Rs. 18 lakhs made by the assessee from the said

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

1, Jalandhar, dated 29/03/2022, where the abovementioned bank account of the assessee held with “ Capital Small Finance Bank” has been examined and some additions has been made on account of unexplained credit entries in such bank , but there is no adverse findings in respect of the investment of Rs. 18 lakhs made by the assessee from the said

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)

IV, Amritsar and also mentioning history of its creation and rating, complete account with bank statement and bank certificate, complete stock fcjtally, invoice with checking on reverse, transportation evidence with RC verifications/proof of export of rice directly under Insurance cover, copying of clearing agents invoice, copy of credit rating, banker certificate of beneficiary account of seller along with the tabulation

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)

IV, Amritsar and also mentioning history of its creation and rating, complete account with bank statement and bank certificate, complete stock fcjtally, invoice with checking on reverse, transportation evidence with RC verifications/proof of export of rice directly under Insurance cover, copying of clearing agents invoice, copy of credit rating, banker certificate of beneficiary account of seller along with the tabulation

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