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21 results for “transfer pricing”+ Section 17(5)(d)clear

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Key Topics

Section 26331Section 143(3)26Addition to Income17Section 10B14Disallowance9Exemption8Section 14A7Section 1476Section 686

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

Section 144C(5) for the assessment year 2021-22. i) The Authorized Representative (AR) also drew the attention of the bench to the reply submitted before the Transfer Pricing Officer (TPO) dated 27.07.2023. In this reply, the assessee had objected to the adjustments made by the TPO, asserting that no such adjustment was required in the prices. Furthermore

Showing 1–20 of 21 · Page 1 of 2

Section 153C6
Section 1324
Unexplained Money4

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

d) ignoring the ratio laid down by the Hon'ble Delhi High Court in the case of Pr. CIT Vs. Kusum Health Care Pvt. Ltd., wherein it has been held that when Assessee has already factored in the impact of the receivables on the working capital and thereby on its 8 I.T.A. Nos. 477 & CO 32/Asr/2015 & Ors Asstt

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

d) ignoring the ratio laid down by the Hon'ble Delhi High Court in the case of Pr. CIT Vs. Kusum Health Care Pvt. Ltd., wherein it has been held that when Assessee has already factored in the impact of the receivables on the working capital and thereby on its 8 I.T.A. Nos. 477 & CO 32/Asr/2015 & Ors Asstt

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

d) ignoring the ratio laid down by the Hon'ble Delhi High Court in the case of Pr. CIT Vs. Kusum Health Care Pvt. Ltd., wherein it has been held that when Assessee has already factored in the impact of the receivables on the working capital and thereby on its 8 I.T.A. Nos. 477 & CO 32/Asr/2015 & Ors Asstt

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

d) ignoring the ratio laid down by the Hon'ble Delhi High Court in the case of Pr. CIT Vs. Kusum Health Care Pvt. Ltd., wherein it has been held that when Assessee has already factored in the impact of the receivables on the working capital and thereby on its 8 I.T.A. Nos. 477 & CO 32/Asr/2015 & Ors Asstt

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

d) ignoring the ratio laid down by the Hon'ble Delhi High Court in the case of Pr. CIT Vs. Kusum Health Care Pvt. Ltd., wherein it has been held that when Assessee has already factored in the impact of the receivables on the working capital and thereby on its 8 I.T.A. Nos. 477 & CO 32/Asr/2015 & Ors Asstt

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

d) ignoring the ratio laid down by the Hon'ble Delhi High Court in the case of Pr. CIT Vs. Kusum Health Care Pvt. Ltd., wherein it has been held that when Assessee has already factored in the impact of the receivables on the working capital and thereby on its 8 I.T.A. Nos. 477 & CO 32/Asr/2015 & Ors Asstt

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

d) ignoring the ratio laid down by the Hon'ble Delhi High Court in the case of Pr. CIT Vs. Kusum Health Care Pvt. Ltd., wherein it has been held that when Assessee has already factored in the impact of the receivables on the working capital and thereby on its 8 I.T.A. Nos. 477 & CO 32/Asr/2015 & Ors Asstt

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

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

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

5. That the Excess stock was arising out of business dealings and as such the provisions of Section 69B, read with Section 115BBE, are not applicable in the instant case 32 17. Per Contra the Ld DR relied on the order of the Ld PCIT, and argued that he was justified in setting aside the order due to the fact

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, 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

D. R. Date of Hearing : 23.07.2025 Date of Pronouncement : 07.08.2025 ORDER Per Udayan Dasgupta, J.M.: This appeal is filed by the Revenue against the order of the ld. CIT(A) NFAC, Delhi dated 11.08.2023 passed u/s 250 of the Income Tax Act, 1961 which has emanated from the order of the AO, Ward 5(4), Amritsar passed

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

D-Mat statement etc. and there is nothing to pinpoint anything against the assessees., High court held that where assessee earned LTCG on sale of shares and AO denied said claim and made additions under section 68 on ground that assessee invested in shares of penny stock companies which provided bogus LTCG, since assessee failed to establish genuineness of rise

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

D-Mat statement etc. and there is nothing to pinpoint anything against the assessees., High court held that where assessee earned LTCG on sale of shares and AO denied said claim and made additions under section 68 on ground that assessee invested in shares of penny stock companies which provided bogus LTCG, since assessee failed to establish genuineness of rise

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

d) The intention of the purchaser of the land is not for agriculture purpose but the same was to earn profit from sale of land as evident from the facts of the case. (e) The land was situated is developed area s nearby A irocity and Airport. (f) The land was purchased by the assessee and the same

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

D, Model Town (Extension), Ludhiana, wherein she had agreed to sell her land admeasuring 09 Kanal - 03 Marla (i.e 5535 sq. yards) situated at Village : Daad, Pakhowal Road, Ludhiana for a consideration of Rs. 7,19,55,000/- 5 Smt. Gurjeet Kaur Vs. ITO-Ward 3(4), Jalandhar ITA No. 627 & 628/Asr/2017 – A.Y 2008-09 & 2009-10 i.e 5

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

D, Model Town (Extension), Ludhiana, wherein she had agreed to sell her land admeasuring 09 Kanal - 03 Marla (i.e 5535 sq. yards) situated at Village : Daad, Pakhowal Road, Ludhiana for a consideration of Rs. 7,19,55,000/- 5 Smt. Gurjeet Kaur Vs. ITO-Ward 3(4), Jalandhar ITA No. 627 & 628/Asr/2017 – A.Y 2008-09 & 2009-10 i.e 5