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22 results for “transfer pricing”+ Section 45(3)clear

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Key Topics

Addition to Income22Section 10B14Section 143(3)9Section 2509Disallowance9Section 1478Section 1328Exemption8Section 14A7

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 of steam and the arm's length pricing is not consistent with the facts and circumstances of the case. Moreover. A.O. erred in reducing the loss @ 20.50% which have already been considered by Assessee. Therefore, in this situation, and in our opinion, the addition made by the Assessing Officer on this account cannot be sustained. Accordingly, the Assessee

Showing 1–20 of 22 · Page 1 of 2

Section 686
Section 806
Search & Seizure6

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 92CA(2B) that assuming but not admitting that excess period of credit allowed by the assessee company on sales made to the subsidiary company is to be treated as an independent international transaction, Ld. Transfer Pricing Officer could not have taken cognizance suo moto of any international transaction for adjustment in the arm's length price u/s 92CA

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 92CA(2B) that assuming but not admitting that excess period of credit allowed by the assessee company on sales made to the subsidiary company is to be treated as an independent international transaction, Ld. Transfer Pricing Officer could not have taken cognizance suo moto of any international transaction for adjustment in the arm's length price u/s 92CA

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 92CA(2B) that assuming but not admitting that excess period of credit allowed by the assessee company on sales made to the subsidiary company is to be treated as an independent international transaction, Ld. Transfer Pricing Officer could not have taken cognizance suo moto of any international transaction for adjustment in the arm's length price u/s 92CA

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 92CA(2B) that assuming but not admitting that excess period of credit allowed by the assessee company on sales made to the subsidiary company is to be treated as an independent international transaction, Ld. Transfer Pricing Officer could not have taken cognizance suo moto of any international transaction for adjustment in the arm's length price u/s 92CA

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 92CA(2B) that assuming but not admitting that excess period of credit allowed by the assessee company on sales made to the subsidiary company is to be treated as an independent international transaction, Ld. Transfer Pricing Officer could not have taken cognizance suo moto of any international transaction for adjustment in the arm's length price u/s 92CA

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 92CA(2B) that assuming but not admitting that excess period of credit allowed by the assessee company on sales made to the subsidiary company is to be treated as an independent international transaction, Ld. Transfer Pricing Officer could not have taken cognizance suo moto of any international transaction for adjustment in the arm's length price u/s 92CA

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 92CA(2B) that assuming but not admitting that excess period of credit allowed by the assessee company on sales made to the subsidiary company is to be treated as an independent international transaction, Ld. Transfer Pricing Officer could not have taken cognizance suo moto of any international transaction for adjustment in the arm's length price u/s 92CA

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

transferring manufactured electricity from C.P.P. unit to its other unit including electricity tax levied by State Electricity Board was price ordinarily prevailing in open market, and, therefore, Commissioner (Appeals) was not justified in disallowing assessee’s claim on said ground - Held, yes - Whether as regards second ground, incomes and expenditures which were not directly relatable to industrial unit 25 I.T.A

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

45) & (56). It has further been held that the Carbon Credits are on the account of savings of energy consumption and not on business. Even while rendering this judgment, the Jaipur Tribunal has discussed the provisions of 115BBG and, thus, since as on the day also, RECs/ESCs are not part of Section 2(24) and, hence, it is a capital

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

3,00,000/- respectively By applying the 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

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

45. Reasons to believe are there. The reasons are based on tangible material. The return and account books of assessee had not undergone scrutiny at the time of assessment. The information is specific and not vague. A reasonable person can form an opinion on the basis of the material. The information received could form the basis of reason to believe

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

price of the new land was more than the sale proceeds of the old land (original asset) there cannot be any capital gains on such sale as per provision of section 54B(1)(ii). He further relied on the judgment of jurisdictional High Court in the case of CIT vs. Gurnam Singh in ITA 616/2007 order dated 01/04/2008 reported

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1, JALANDHAR vs. SHRI JATINDER SINGH BEDI , JALANDHAR

In the result, the appeal of the revenue, ITA No 90/Asr/2020 is dismissed

ITA 90/ASR/2020[2017-18]Status: DisposedITAT Amritsar11 Apr 2023AY 2017-18

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

Section 132Section 139Section 153ASection 250Section 69A

transferred and registration of 3 Kanal 10 Marla was executed on 18.05.2018 for Rs.42 lacs and the balance property including the building & others are still in possession & power of M/s. S. Amar Singh Educational Charitable Trust. The electricity bill of the institute is still in the name of GNA-IMT which, as per the AR, justifies the claims

SHRI BHAVNOOR SINGH BEDI,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, JALANDHAR

In the result, the appeal of the revenue, ITA No 90/Asr/2020 is dismissed

ITA 53/ASR/2020[2016-17]Status: DisposedITAT Amritsar11 Apr 2023AY 2016-17

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

Section 132Section 139Section 153ASection 250Section 69A

transferred and registration of 3 Kanal 10 Marla was executed on 18.05.2018 for Rs.42 lacs and the balance property including the building & others are still in possession & power of M/s. S. Amar Singh Educational Charitable Trust. The electricity bill of the institute is still in the name of GNA-IMT which, as per the AR, justifies the claims

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1, JALANDHAR vs. SHRI BHAVNOOR SINGH BEDI, JALANDHAR

In the result, the appeal of the revenue, ITA No 90/Asr/2020 is dismissed

ITA 87/ASR/2020[2016-17]Status: DisposedITAT Amritsar11 Apr 2023AY 2016-17

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

Section 132Section 139Section 153ASection 250Section 69A

transferred and registration of 3 Kanal 10 Marla was executed on 18.05.2018 for Rs.42 lacs and the balance property including the building & others are still in possession & power of M/s. S. Amar Singh Educational Charitable Trust. The electricity bill of the institute is still in the name of GNA-IMT which, as per the AR, justifies the claims

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1, JALANDHAR vs. SHRI BHAVNOOR SINGH BEDI, JALANDHAR

In the result, the appeal of the revenue, ITA No 90/Asr/2020 is dismissed

ITA 88/ASR/2020[2017-18]Status: DisposedITAT Amritsar11 Apr 2023AY 2017-18

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

Section 132Section 139Section 153ASection 250Section 69A

transferred and registration of 3 Kanal 10 Marla was executed on 18.05.2018 for Rs.42 lacs and the balance property including the building & others are still in possession & power of M/s. S. Amar Singh Educational Charitable Trust. The electricity bill of the institute is still in the name of GNA-IMT which, as per the AR, justifies the claims

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1, JALANDHAR vs. SHRI JATINDER SINGH BEDI, JALANDHAR

In the result, the appeal of the revenue, ITA No 90/Asr/2020 is dismissed

ITA 89/ASR/2020[2016-17]Status: DisposedITAT Amritsar11 Apr 2023AY 2016-17

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

Section 132Section 139Section 153ASection 250Section 69A

transferred and registration of 3 Kanal 10 Marla was executed on 18.05.2018 for Rs.42 lacs and the balance property including the building & others are still in possession & power of M/s. S. Amar Singh Educational Charitable Trust. The electricity bill of the institute is still in the name of GNA-IMT which, as per the AR, justifies the claims

SHRI BHAVNOOR SINGH BEDI,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, JALANDHAR

In the result, the appeal of the revenue, ITA No 90/Asr/2020 is dismissed

ITA 51/ASR/2020[2014-15]Status: DisposedITAT Amritsar11 Apr 2023AY 2014-15

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

Section 132Section 139Section 153ASection 250Section 69A

transferred and registration of 3 Kanal 10 Marla was executed on 18.05.2018 for Rs.42 lacs and the balance property including the building & others are still in possession & power of M/s. S. Amar Singh Educational Charitable Trust. The electricity bill of the institute is still in the name of GNA-IMT which, as per the AR, justifies the claims

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

price and duty drawback. In view of the\ndecision of Supreme Court in the case of Keshavji Ravji & Co vs. CIT\nreported at 183 ITR 1 the duty drawback should be reduced from the\nvalue of purchases as a result of which the profits earned from exports\nwill only be in respect of value of sales credited to the Manufacturing