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55 results for “transfer pricing”+ Section 5(2)clear

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Key Topics

Section 26358Section 143(3)53Addition to Income47Section 153(4)28Section 14824Section 6916Section 13215Section 25014Section 10B14

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

Section 144C(5) for the assessment year 2021-22. i) The Authorized Representative (AR) also drew the attention of the bench to the reply submitted before the Transfer Pricing Officer (TPO) dated 27.07.2023. In this reply, the assessee had objected to the adjustments made by the TPO, asserting that no such adjustment was required in the prices. Furthermore

Showing 1–20 of 55 · Page 1 of 3

Disallowance12
Search & Seizure9
Limitation/Time-bar8

MAX FINANCIAL SERVICE LIMITED ,NAWANSHAHR vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, JALANDHAR

In the result, the appeal of the assessee is therefore partly allowed

ITA 121/ASR/2020[2015-16]Status: DisposedITAT Amritsar31 Mar 2021AY 2015-16
For Appellant: Shri Deepak ChopraFor Respondent: Smt.Prabhjot Kaur, CIT
Section 143(3)Section 263

5) CIT Vs. New India Maritime Agencies (1994) 207 ITR 392(Mad) 22. It has been consistently held by courts in the aforestated decisions that where a house property is occupied as residence by employees or its directors to 18 A.Y.2015-16 enable them to discharge their functions effectively and the letting out is subservient and incidental to the main business

SH. MANJIT KRISHAN MALHOTRA,ABOHAR vs. PR. COMMISSIONER OF INCME TAX , BATHINDA

The appeals of the assessee are disposed of in the terms indicated as above

ITA 39/ASR/2019[2008-09]Status: DisposedITAT Amritsar11 Aug 2022AY 2008-09

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

For Appellant: Sh. Anil Puri, AdvFor Respondent: Sh. Chandrajit Singh, CIT DR
Section 263Section 269SSection 271D

Transfer Pricing Officer, as the case may be,] conferred on, or assigned to, him under the orders or directions issued by the Board or by the 92[Principal Chief Commissioner or] Chief Commissioner or 92[Principal Director General or] Director General or 92[Principal Commissioner or] Commissioner authorised by the Board in this behalf under section 120; 15. Accordingly

SHRI. MANJIT KRISHAN MALHOTRA,ABOHAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, BATHINDA

The appeals of the assessee are disposed of in the terms indicated as above

ITA 40/ASR/2019[2008-09]Status: DisposedITAT Amritsar11 Aug 2022AY 2008-09

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

For Appellant: Sh. Anil Puri, AdvFor Respondent: Sh. Chandrajit Singh, CIT DR
Section 263Section 269SSection 271D

Transfer Pricing Officer, as the case may be,] conferred on, or assigned to, him under the orders or directions issued by the Board or by the 92[Principal Chief Commissioner or] Chief Commissioner or 92[Principal Director General or] Director General or 92[Principal Commissioner or] Commissioner authorised by the Board in this behalf under section 120; 15. Accordingly

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 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

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 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 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

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

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

section 144C(13) in consequence of directions of DRP u/s144C(5) of the Income Tax Act, 1961. 2. That the Assessing Officer (AO) has erred in making an addition of Rs. 6,66,54,028/- by reducing the sales value of steam and power to Rs. 56,08,22,355, contrary to the audited results declared

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

ITA 16/ASR/2017[1985-86]Status: DisposedITAT Amritsar20 Dec 2022AY 1985-86

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

Section 143(3)Section 148Section 153(4)

section 153(4) is related to the transfer pricing u/s 92CA. But the issue of the assessee is related to domestic tax which is not related to transfer pricing. The entire issue is raised before the bench first time without agitating before the lower authority. The submission of the ld. Sr Dr is in view that the assessment orders

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

ITA 22/ASR/2017[1991-92]Status: DisposedITAT Amritsar20 Dec 2022AY 1991-92

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

Section 143(3)Section 148Section 153(4)

section 153(4) is related to the transfer pricing u/s 92CA. But the issue of the assessee is related to domestic tax which is not related to transfer pricing. The entire issue is raised before the bench first time without agitating before the lower authority. The submission of the ld. Sr Dr is in view that the assessment orders

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

ITA 19/ASR/2017[1988-89]Status: DisposedITAT Amritsar20 Dec 2022AY 1988-89

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

Section 143(3)Section 148Section 153(4)

section 153(4) is related to the transfer pricing u/s 92CA. But the issue of the assessee is related to domestic tax which is not related to transfer pricing. The entire issue is raised before the bench first time without agitating before the lower authority. The submission of the ld. Sr Dr is in view that the assessment orders

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

ITA 21/ASR/2017[1990-91]Status: DisposedITAT Amritsar20 Dec 2022AY 1990-91

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

Section 143(3)Section 148Section 153(4)

section 153(4) is related to the transfer pricing u/s 92CA. But the issue of the assessee is related to domestic tax which is not related to transfer pricing. The entire issue is raised before the bench first time without agitating before the lower authority. The submission of the ld. Sr Dr is in view that the assessment orders

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

ITA 17/ASR/2017[1986-87]Status: DisposedITAT Amritsar20 Dec 2022AY 1986-87

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

Section 143(3)Section 148Section 153(4)

section 153(4) is related to the transfer pricing u/s 92CA. But the issue of the assessee is related to domestic tax which is not related to transfer pricing. The entire issue is raised before the bench first time without agitating before the lower authority. The submission of the ld. Sr Dr is in view that the assessment orders

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

ITA 15/ASR/2017[1984-85]Status: DisposedITAT Amritsar20 Dec 2022AY 1984-85

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

Section 143(3)Section 148Section 153(4)

section 153(4) is related to the transfer pricing u/s 92CA. But the issue of the assessee is related to domestic tax which is not related to transfer pricing. The entire issue is raised before the bench first time without agitating before the lower authority. The submission of the ld. Sr Dr is in view that the assessment orders

M/S SADHU SINGH HAMDARD TRUST,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeals of the assessee bearing ITA Nos

ITA 18/ASR/2017[1987-88]Status: DisposedITAT Amritsar20 Dec 2022AY 1987-88

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

Section 143(3)Section 148Section 153(4)

section 153(4) is related to the transfer pricing u/s 92CA. But the issue of the assessee is related to domestic tax which is not related to transfer pricing. The entire issue is raised before the bench first time without agitating before the lower authority. The submission of the ld. Sr Dr is in view that the assessment orders