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9 results for “transfer pricing”+ Section 77clear

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Key Topics

Section 26323Section 143(3)20Addition to Income8Section 695Section 132(4)4Section 69C3Section 1323Section 115B2Section 144C(13)

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

2
Business Income2
Survey u/s 133A2
Bogus/Accommodation Entry2

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

77,26,000/- by transferring of the RECs and ESCs credit during the impugned year which is capital in nature. Though in the return the assessee claimed it u/s 115BBG and paid the tax in special rate. 5.1 Mr Sehgal, ld. AR invited our attention in APB pages 7 to 15, the copy of the letter dated 26.09.2021 submitted before

POONAM MARWAHA,AMRITSAR vs. ACIT DCIT CEN CIR, AMRITSAR

In the result, the appeal filed by assessee is allowed

ITA 306/ASR/2024[2019-20]Status: DisposedITAT Amritsar09 Jan 2025AY 2019-20
Section 115BSection 143(3)Section 263Section 263(1)Section 69

77,416/-\n13,86,384/-\n15,60,000/-\nNIL\n22.\nThat before invoking the provisions of section 263, it is very much necessary\nto adhere to the twin conditions as embedded in section 263. In the circumstances\nwhere only one of the conditions is satisfied and the condition is not dealt with, in\nsuch circumstances the proceedings initiated vide section

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

price of impugned land purchase, ignoring the detailed discussion of the same in the assessment order; that the Ld. CIT(A) is not right to 15 I.T.A. No.557/Asr/2024 Assessment Year: 2019-20 hold that various ikrarnamas, photocopies of which were found and seized during search viz. A-9 DNB-1 are collusive in nature, as claimed by the assessee, when

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR vs. M/S PUNJAB RICE LAND PRIVATE LIMITED, TARN TARAN

In the result, both the appeals of the revenue are dismissed and

ITA 45/ASR/2021[2014-15]Status: DisposedITAT Amritsar15 Nov 2022AY 2014-15

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

For Appellant: Sh. Jatinder Nagpal, Adv. & Sh. Nimish Nagpal, CAFor Respondent: Sh. Rohit Mehra, CIT DR
Section 132(4)

section 151 of the Act." Notice u/s 148 of the I.T.Act,1961 was issued on 30.03.2018 and served on assessee on 30.03.2018. In response to the notice u/s 148, assessee e-filed his return on 26.12.2018 at a income of Rs. 77,66,950/-. Notice u/s 143(2) was issued on 15.10.2018, fixing the case for hearing

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, AMRITSAR vs. M/S PUNJAB RICE LAND PRIVATE LIMITED , TARN TARAN

In the result, both the appeals of the revenue are dismissed and

ITA 44/ASR/2021[2012-13]Status: DisposedITAT Amritsar15 Nov 2022AY 2012-13

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

For Appellant: Sh. Jatinder Nagpal, Adv. & Sh. Nimish Nagpal, CAFor Respondent: Sh. Rohit Mehra, CIT DR
Section 132(4)

section 151 of the Act." Notice u/s 148 of the I.T.Act,1961 was issued on 30.03.2018 and served on assessee on 30.03.2018. In response to the notice u/s 148, assessee e-filed his return on 26.12.2018 at a income of Rs. 77,66,950/-. Notice u/s 143(2) was issued on 15.10.2018, fixing the case for hearing

SMT. INDERMEET BAINS W/O SH. D.S. BAINS,BATHINDA vs. PR. COMMISSIONER OF INCOME TAX , BATHINDA

The appeal of the assessee is disposed of in the term indicated as above

ITA 250/ASR/2019[2011-12]Status: DisposedITAT Amritsar19 Oct 2022AY 2011-12

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

For Appellant: Sh. Sudhir Sehgal & Sh. P.N. Arora, AdvFor Respondent: Sh. Amlendu Nath Misra, CIT DR
Section 143(3)Section 263

77 Taxmann.com 15 and it was held that, where the view has been taken by the Assessing Officer, after making proper/requisite enquiries, the order u/s 263 cannot be sustained. Copy of the said judgment has been placed in 14 Indermeet Bains v. Pr. CIT Paper Book at pages 217 to 226 of Paper Book. The assessee also relied upon

SMT. GURJEET KAUR,JALANDHAR vs. INCOME TAX OFFICER, WARD- IV (2),, JALANDHAR

The appeal of the assessee is allowed in terms of our

ITA 627/ASR/2017[2008-09]Status: DisposedITAT Amritsar21 Feb 2022AY 2008-09

Bench: Sh. Ravish Sood & Dr. M. L. Meena

For Appellant: Sh. Surinder Mahajan, CAFor Respondent: Sh. Sunil Gautam, CIT-DR
Section 143(3)Section 147Section 69Section 91

transferred from his bank account. Backed by his aforesaid observations, the A.O acting upon the contents of the “agreement to sell”, therein, held the amount of Rs. 1.50 crore received by the assessee as 8 Smt. Gurjeet Kaur Vs. ITO-Ward 3(4), Jalandhar ITA No. 627 & 628/Asr/2017 – A.Y 2008-09 & 2009-10 earnest money from Sh. Surjit Singh (supra

SMT. GURJEET KAUR,JALANDHAR vs. INCOME TAX OFFICER, WARD- IV (2),, JALANDHAR

The appeal of the assessee is allowed in terms of our

ITA 628/ASR/2017[2009-10]Status: DisposedITAT Amritsar21 Feb 2022AY 2009-10

Bench: Sh. Ravish Sood & Dr. M. L. Meena

For Appellant: Sh. Surinder Mahajan, CAFor Respondent: Sh. Sunil Gautam, CIT-DR
Section 143(3)Section 147Section 69Section 91

transferred from his bank account. Backed by his aforesaid observations, the A.O acting upon the contents of the “agreement to sell”, therein, held the amount of Rs. 1.50 crore received by the assessee as 8 Smt. Gurjeet Kaur Vs. ITO-Ward 3(4), Jalandhar ITA No. 627 & 628/Asr/2017 – A.Y 2008-09 & 2009-10 earnest money from Sh. Surjit Singh (supra