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32 results for “transfer pricing”+ Section 2clear

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Key Topics

Addition to Income31Section 26321Section 143(3)19Section 10B14Section 6914Section 13213Section 25012Disallowance10Section 1479

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 adjustments. 5.2 The assessee has established two captive electricity and steam generation units (referred to as Co-generation Unit 1 and Co- generation Unit 2) located in Muktsar, Punjab, for the generation of electricity and steam. The assessee has sought exemption under Section

Showing 1–20 of 32 · Page 1 of 2

Section 1489
Exemption8
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

2. That Ld. CIT(A) ought to have held that in any case, reference made to Transfer Pricing Officer without demonstrating as to why it was necessary and expedient to do so is bad in law. 3. That Ld. ClT(A) is not justified in rejecting the objection of the assessee company citing provisions of section

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

2. That Ld. CIT(A) ought to have held that in any case, reference made to Transfer Pricing Officer without demonstrating as to why it was necessary and expedient to do so is bad in law. 3. That Ld. ClT(A) is not justified in rejecting the objection of the assessee company citing provisions of section

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

2. That Ld. CIT(A) ought to have held that in any case, reference made to Transfer Pricing Officer without demonstrating as to why it was necessary and expedient to do so is bad in law. 3. That Ld. ClT(A) is not justified in rejecting the objection of the assessee company citing provisions of section

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

2. That Ld. CIT(A) ought to have held that in any case, reference made to Transfer Pricing Officer without demonstrating as to why it was necessary and expedient to do so is bad in law. 3. That Ld. ClT(A) is not justified in rejecting the objection of the assessee company citing provisions of section

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

2. That Ld. CIT(A) ought to have held that in any case, reference made to Transfer Pricing Officer without demonstrating as to why it was necessary and expedient to do so is bad in law. 3. That Ld. ClT(A) is not justified in rejecting the objection of the assessee company citing provisions of section

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

2. That Ld. CIT(A) ought to have held that in any case, reference made to Transfer Pricing Officer without demonstrating as to why it was necessary and expedient to do so is bad in law. 3. That Ld. ClT(A) is not justified in rejecting the objection of the assessee company citing provisions of section

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

2. That Ld. CIT(A) ought to have held that in any case, reference made to Transfer Pricing Officer without demonstrating as to why it was necessary and expedient to do so is bad in law. 3. That Ld. ClT(A) is not justified in rejecting the objection of the assessee company citing provisions of section

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

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

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

pricing adjustments ,vide order u/s 92CA(3) dated 30/10/2023. 2. Brief facts emerging from records , are that the assessee company is engaged in manufacturing of paper and paper based products at its unit at Muktsar, Punjab, utilizing wood chips, veneer waste, wheat straw and other materials as inputs ( wood and agro based manufacturer ) and for the purpose of its manufacturing

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

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

2. That while taking the above view, the ld.CIT(A) was not justified in totally ignoring the binding decision of Hon'ble Supreme Court in Rajinder Nath vs CIT (1979) 120 ITR 14 (SC), heavily relied upon by assessee, holding that 'when it is left to the option or discretion of the ITO, whether or not to take an action

THE DY. COMMISSIONER INCOME-TAX, JAMMU vs. M/S. HORIZON BUILDCON PVT. LTD,, JAMMU

In the result, the appeals of the Revenue in I

ITA 672/ASR/2014[201-11]Status: DisposedITAT Amritsar22 Mar 2023

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

For Appellant: Sh. Hitendra Bhauraoji Ninawe, CIT DRFor Respondent: S/Sh. P.N. Arora, Adv., Pradeep
Section 69

price bargained for by the parties to the sale, etc. The consideration for the transfer of the capital asset is what the transferor receives Dy. CIT v. Horizon Buildcon Pvt. Ltd. in lieu of the asset he parts with, viz., money or money's worth. The expression "full consideration" in the main part of section 12B(2

THE DY. COMMISSIONER INCOME-TAX, JAMMU vs. M/S. HORIZON BUILDCON PVT. LTD,, JAMMU

In the result, the appeals of the Revenue in I

ITA 671/ASR/2014[2009-10]Status: DisposedITAT Amritsar22 Mar 2023AY 2009-10

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

For Appellant: Sh. Hitendra Bhauraoji Ninawe, CIT DRFor Respondent: S/Sh. P.N. Arora, Adv., Pradeep
Section 69

price bargained for by the parties to the sale, etc. The consideration for the transfer of the capital asset is what the transferor receives Dy. CIT v. Horizon Buildcon Pvt. Ltd. in lieu of the asset he parts with, viz., money or money's worth. The expression "full consideration" in the main part of section 12B(2

THE DY. COMMISSIONER INCOME-TAX, JAMMU vs. M/S. HORIZON BUILDCON PVT. LTD,, JAMMU

In the result, the appeals of the Revenue in I

ITA 673/ASR/2014[2011-12]Status: DisposedITAT Amritsar22 Mar 2023AY 2011-12

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

For Appellant: Sh. Hitendra Bhauraoji Ninawe, CIT DRFor Respondent: S/Sh. P.N. Arora, Adv., Pradeep
Section 69

price bargained for by the parties to the sale, etc. The consideration for the transfer of the capital asset is what the transferor receives Dy. CIT v. Horizon Buildcon Pvt. Ltd. in lieu of the asset he parts with, viz., money or money's worth. The expression "full consideration" in the main part of section 12B(2

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

2) of\nsection 75 of Customs Act requires the amount of draw back to be\ndetermined on a consideration of all the circumstances prevalent in a\nparticular trade and also based on the facts situation relevant in\nrespect of each of various classes of goods imported. Basically, the\nsource of duty draw back receipt lies in section 75 of Customs

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

price index on purchase value, indexed cost comes to Rs 8.800/- and Rs.792,000/- respectively. But the appellant credited his account with amount of Rs.2.55,00,000/- instead of Rs 8,00,800/- without paying any tax Therefore the appellant was given final opportunity to explain as to why the amount of Rs 2.45.99,200/- (Rs 2

SHRI SUBASH CHANDER GUPTA & SONS,JAMMU vs. PRINCIPAL COMMISSINER OF INCOME TAX , SRINAGAR

In the result, the appeal filed by the assessee is allowed

ITA 37/ASR/2021[2015-16]Status: DisposedITAT Amritsar13 Sept 2023AY 2015-16

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

For Appellant: Sh. Vinamar Gupta, CAFor Respondent: Sh. Hitendra Bhauraoji Ninawe, CIT DR
Section 164Section 263

2. At the outset, the learned counsel for the appellant has submitted that as per the language of the section 263 it is apparently clear that opportunity of being heard has to be provided by Commissioner himself by way of issue of notice and show cause notices under section 263 of the Act and no other officer can perform this

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

section 54B is available for any land which is utilised for the purpose of agriculture for atleast two years immediately preceding the date on which the transfer took place. In the instant case it is not disputed that the appellant was cultivating the said land. The appellant in his written submissions has produced the revenue record as proof of doing

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