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14 results for “transfer pricing”+ Section 35(1)(i)clear

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Key Topics

Section 10B14Addition to Income14Section 143(3)10Disallowance10Exemption8Section 14A7Section 1325Section 1485Section 1474

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

Section 69C3
Section 693
Survey u/s 133A2

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

section 10B is rejected. 18. In the next issue, revenue has challenged that CIT(A) has ignored the findings of the TPO and applied LIBOR, for rate on interest advanced to Associate Enterprises in US and thereby deleting the addition of Rs. 1,48,40,164/- on account of interest on loan advanced to the AE and addition of Rs.76

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

section 10B is rejected. 18. In the next issue, revenue has challenged that CIT(A) has ignored the findings of the TPO and applied LIBOR, for rate on interest advanced to Associate Enterprises in US and thereby deleting the addition of Rs. 1,48,40,164/- on account of interest on loan advanced to the AE and addition of Rs.76

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

section 10B is rejected. 18. In the next issue, revenue has challenged that CIT(A) has ignored the findings of the TPO and applied LIBOR, for rate on interest advanced to Associate Enterprises in US and thereby deleting the addition of Rs. 1,48,40,164/- on account of interest on loan advanced to the AE and addition of Rs.76

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

section 10B is rejected. 18. In the next issue, revenue has challenged that CIT(A) has ignored the findings of the TPO and applied LIBOR, for rate on interest advanced to Associate Enterprises in US and thereby deleting the addition of Rs. 1,48,40,164/- on account of interest on loan advanced to the AE and addition of Rs.76

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

section 10B is rejected. 18. In the next issue, revenue has challenged that CIT(A) has ignored the findings of the TPO and applied LIBOR, for rate on interest advanced to Associate Enterprises in US and thereby deleting the addition of Rs. 1,48,40,164/- on account of interest on loan advanced to the AE and addition of Rs.76

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

section 10B is rejected. 18. In the next issue, revenue has challenged that CIT(A) has ignored the findings of the TPO and applied LIBOR, for rate on interest advanced to Associate Enterprises in US and thereby deleting the addition of Rs. 1,48,40,164/- on account of interest on loan advanced to the AE and addition of Rs.76

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

section 10B is rejected. 18. In the next issue, revenue has challenged that CIT(A) has ignored the findings of the TPO and applied LIBOR, for rate on interest advanced to Associate Enterprises in US and thereby deleting the addition of Rs. 1,48,40,164/- on account of interest on loan advanced to the AE and addition of Rs.76

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

Section 139 (5) of the Act was filed before the Assessing Officer. We answer both the question Nos. 1 and 2 in negative and in favour of assessee”. Ground No. 3 9. Ground No. 3, not pressed. Ground Nos. 4 & 5 I.T.A. No.193/Asr/2022 32 Assessment Year: 2018-19 10. The ld. AR argued that the assessee paidcommission during financial year

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

35. The price at which the State Electricity Board supplies electricity to industrial consumers should be adopted as the market value for computing deduction under section 80-IA. In terms of section 80-IA(8) and the definition of “market value,” it is evident that the rate charged to industrial consumers represents the appropriate benchmark. Accordingly, the assessee, maintaining separate

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

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

section 68. 20. Per contra, the Ld. DR supported the impugned order. He contended that the AO observed that the amounts which the assessee paid over and above the prices mentioned in the registries of purchase of land by the assessee company during FY 2008-09 were amounting to a sum of Rs 216,23,000/-, being the cash deposited

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

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