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11 results for “transfer pricing”+ Section 42clear

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Key Topics

Section 10B14Addition to Income11Section 143(3)8Exemption8Disallowance8Section 14A7Section 69C3Section 92C3Section 80I3

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

Section 803
Section 1322
Deduction2

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

Transfer Pricing Assessment, it is evident that the TPO has applied interest rate of 17.26% to compute Arms length interest on loan advanced to AE without any comparable, and thus the view of the AO based on the aforesaid TPO report would not be justified. The CIT(A) has relied on the ITAT, Mumbai in the case of ACIT

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

Transfer Pricing Assessment, it is evident that the TPO has applied interest rate of 17.26% to compute Arms length interest on loan advanced to AE without any comparable, and thus the view of the AO based on the aforesaid TPO report would not be justified. The CIT(A) has relied on the ITAT, Mumbai in the case of ACIT

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

Transfer Pricing Assessment, it is evident that the TPO has applied interest rate of 17.26% to compute Arms length interest on loan advanced to AE without any comparable, and thus the view of the AO based on the aforesaid TPO report would not be justified. The CIT(A) has relied on the ITAT, Mumbai in the case of ACIT

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

Transfer Pricing Assessment, it is evident that the TPO has applied interest rate of 17.26% to compute Arms length interest on loan advanced to AE without any comparable, and thus the view of the AO based on the aforesaid TPO report would not be justified. The CIT(A) has relied on the ITAT, Mumbai in the case of ACIT

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

Transfer Pricing Assessment, it is evident that the TPO has applied interest rate of 17.26% to compute Arms length interest on loan advanced to AE without any comparable, and thus the view of the AO based on the aforesaid TPO report would not be justified. The CIT(A) has relied on the ITAT, Mumbai in the case of ACIT

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

Transfer Pricing Assessment, it is evident that the TPO has applied interest rate of 17.26% to compute Arms length interest on loan advanced to AE without any comparable, and thus the view of the AO based on the aforesaid TPO report would not be justified. The CIT(A) has relied on the ITAT, Mumbai in the case of ACIT

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

Transfer Pricing Assessment, it is evident that the TPO has applied interest rate of 17.26% to compute Arms length interest on loan advanced to AE without any comparable, and thus the view of the AO based on the aforesaid TPO report would not be justified. The CIT(A) has relied on the ITAT, Mumbai in the case of ACIT

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

Section 80-IA(8) - HELD THAT:- We are of the considered view that the method adopted by the Assessee for determining the arm's length price was correct, and the adjustments made by the AO were not in line with the applicable provisions of the Income Tax Act. Therefore, in this situation, and in our opinion, the addition made

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

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