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13 results for “transfer pricing”+ Section 72clear

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Key Topics

Addition to Income13Section 699Section 2507Section 153A6Section 1396Section 1326Section 69A6Search & Seizure6Section 143(3)

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

72,90,275 from the assessee's reported value of Rs. 41,21,19^626. Ground No. 8 addresses the change in the transfer pricing method from the Transaction Net Margin Method (TNMM) to 527-Asr-2024 Satia Industries, Muktsar 9 the External Comparable Uncontrolled Price (CUP) method, which could affect the determination of the arm's length price

5
Section 493
Disallowance2
Deduction2

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 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

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 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

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

72-73, Joshi Colony, The Mall P.O. GPO Civil Lines, Amritsar Punjab 143001 [PAN: AAWPM 5565A] (Appellant) (Respondent) Appellant by : Sh. Jatinder Nagpal, Adv. : Respondent by Sh. Charan Dass, Sr. D. R. Date of Hearing : 23.07.2025 Date of Pronouncement : 07.08.2025 ORDER Per Udayan Dasgupta, J.M.: This appeal is filed by the Revenue against the order

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

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

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

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

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

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