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27 results for “transfer pricing”+ Section 27clear

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Key Topics

Addition to Income27Section 143(3)15Section 10B14Section 6914Section 13213Section 26310Disallowance10Section 1478Section 2508

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 Officer (in short ‘TPO’) dated 5.12.2021 for A.Y. 2020-21. 2. Brief facts of the case, as per the order/directions of the Dispute Resolution Panel-1, New Delhi [herein referred to as ‘DRP’ ] dated 24.06.2024 for A.Y. 2020-21 are as under:- “Profile of the Assessee: Satia Industries Limited (hereinafter referred as 'the Assessee

Showing 1–20 of 27 · 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

27,636/- under the Duty Drawback u/s 10B of the Act after crediting the said receipts of the aforesaid amounts into the Profit & Loss Account under Sections 28(iiic) and 28(iiib) of the Act. The AO disallowed the aforesaid claim of deduction under section 10B of the Act following the Hon’ble Apex Court Judgement in “Liberty India

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

27,636/- under the Duty Drawback u/s 10B of the Act after crediting the said receipts of the aforesaid amounts into the Profit & Loss Account under Sections 28(iiic) and 28(iiib) of the Act. The AO disallowed the aforesaid claim of deduction under section 10B of the Act following the Hon’ble Apex Court Judgement in “Liberty India

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

27,636/- under the Duty Drawback u/s 10B of the Act after crediting the said receipts of the aforesaid amounts into the Profit & Loss Account under Sections 28(iiic) and 28(iiib) of the Act. The AO disallowed the aforesaid claim of deduction under section 10B of the Act following the Hon’ble Apex Court Judgement in “Liberty India

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

27,636/- under the Duty Drawback u/s 10B of the Act after crediting the said receipts of the aforesaid amounts into the Profit & Loss Account under Sections 28(iiic) and 28(iiib) of the Act. The AO disallowed the aforesaid claim of deduction under section 10B of the Act following the Hon’ble Apex Court Judgement in “Liberty India

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

27,636/- under the Duty Drawback u/s 10B of the Act after crediting the said receipts of the aforesaid amounts into the Profit & Loss Account under Sections 28(iiic) and 28(iiib) of the Act. The AO disallowed the aforesaid claim of deduction under section 10B of the Act following the Hon’ble Apex Court Judgement in “Liberty India

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

27,636/- under the Duty Drawback u/s 10B of the Act after crediting the said receipts of the aforesaid amounts into the Profit & Loss Account under Sections 28(iiic) and 28(iiib) of the Act. The AO disallowed the aforesaid claim of deduction under section 10B of the Act following the Hon’ble Apex Court Judgement in “Liberty India

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

27,636/- under the Duty Drawback u/s 10B of the Act after crediting the said receipts of the aforesaid amounts into the Profit & Loss Account under Sections 28(iiic) and 28(iiib) of the Act. The AO disallowed the aforesaid claim of deduction under section 10B of the Act following the Hon’ble Apex Court Judgement in “Liberty India

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

transferred to paper unit, in that circumstances the arm length rate works out to 3,18,91,85,267.04. 26. He further referred to the TPO order for the Assessment Year 2017-18 wherein the department accepted the price of electricity at Rs. 6.87 per KWH (calculated as 43,60,95,829/ 6,34,63,979) and the position

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

transferred. The Hon'ble Madras High Court in the case of CIT Vs. P. Suryanaraina 88 ITR 321 held that the full value of consideration in the said section meant only the actual value received by the assessee. However the market value may also be taken in place of full value of consideration only in the event of the consideration

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

transferred. The Hon'ble Madras High Court in the case of CIT Vs. P. Suryanaraina 88 ITR 321 held that the full value of consideration in the said section meant only the actual value received by the assessee. However the market value may also be taken in place of full value of consideration only in the event of the consideration

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

transferred. The Hon'ble Madras High Court in the case of CIT Vs. P. Suryanaraina 88 ITR 321 held that the full value of consideration in the said section meant only the actual value received by the assessee. However the market value may also be taken in place of full value of consideration only in the event of the consideration

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

price. Thus, the Panel is of the view that the assessee has wrongly claimed the Income from Sale of RECs/ESCs u/s 115BBG of Income Tax Act, I.T.A. No.193/Asr/2022 22 Assessment Year: 2018-19 1961. Income from sale of REC/ESCs is normal business income few the assessee and needs to be included in the business income and taxed at normal tale

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

27 of the order u/s 263 ) and he relied on various judicial decisions\ncontained in the revision order u/s 263 of the Act dated 19/03/2024.\n18.\nThe Ld. AR of the assessee in rejoinder submitted that it is a settled law that\nthe provisions of section 263 can only be invoked where both the condition vis\n'prejudicial

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

section 69, on basis of uncertified copy of an agreement to sell was not justified Further, the Hon'ble High Court of Delhi in the case of Principal Commissioner of Income Tax vs. Smt. Rashmi Rajiv Mehta reported in [2024] 160 taxmann.com 723 (Delhi) has held as under: Assessing Officer based on said information issued reopening notice and made addition

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

transfer of long term securities (Share dealings) - Assessment year 2013-14 - Assessee had sold shares of SNCFL and earned long-term capital gains - Assessing Officer issued a show cause notice alleging that transaction was a pennystock deal aimed at illegitimately claiming long-term capital gain exemption under section 10(38) - Assessing Officer treated purchase as bogus and added

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

transfer of long term securities (Share dealings) - Assessment year 2013-14 - Assessee had sold shares of SNCFL and earned long-term capital gains - Assessing Officer issued a show cause notice alleging that transaction was a pennystock deal aimed at illegitimately claiming long-term capital gain exemption under section 10(38) - Assessing Officer treated purchase as bogus and added

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

27 lakh on 04-04-2008 Sh Gursharn Singh In S B A/C 81002200011484 of Sh Gurmukh Singh In S B A/c No. 81002200011470 53,98,000/- on 04-04- of Sh Malook Singh 2008 It was only in the account statements of the above persons that the above entries were reflected as by transfer due to technical fault

SHRI JASBIR SINGH ,AMRITSAR vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR

In the result, appeal of the assesseeITA No

ITA 133/ASR/2022[2019-20]Status: DisposedITAT Amritsar07 Aug 2023AY 2019-20

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No. 133/Asr/2022 Assessment Year: 2019-20

Section 143(3)Section 250Section 69

price whichever is lower at the acquisition in the past. 4. That Ld. AO has not appreciated the fact that surrender was agreed in the hands of four persons to avoid litigation, buy peace and to make amicable settlement with the department. 5. That the Ld. AO erred under law and facts in making addition of Rs. 27

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