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13 results for “transfer pricing”+ Section 90(2)clear

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Key Topics

Section 10B14Addition to Income13Exemption8Disallowance8Section 14A7Section 143(3)7Section 686Section 806Section 1474

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

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 and, consequently

Section 1324
Section 1484
Deduction3

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

90. This is the formula which has been provided by sub section (4) for the purpose of working out the benefit or deduction under sub section. (1). 4. Your Honour, Legislature has not provided for excluding the amount of export incentive from profits of the business while calculating deduction u/s 10B. The position is somewhat akin or close to Section

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

90. This is the formula which has been provided by sub section (4) for the purpose of working out the benefit or deduction under sub section. (1). 4. Your Honour, Legislature has not provided for excluding the amount of export incentive from profits of the business while calculating deduction u/s 10B. The position is somewhat akin or close to Section

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

90. This is the formula which has been provided by sub section (4) for the purpose of working out the benefit or deduction under sub section. (1). 4. Your Honour, Legislature has not provided for excluding the amount of export incentive from profits of the business while calculating deduction u/s 10B. The position is somewhat akin or close to Section

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

90. This is the formula which has been provided by sub section (4) for the purpose of working out the benefit or deduction under sub section. (1). 4. Your Honour, Legislature has not provided for excluding the amount of export incentive from profits of the business while calculating deduction u/s 10B. The position is somewhat akin or close to Section

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

90. This is the formula which has been provided by sub section (4) for the purpose of working out the benefit or deduction under sub section. (1). 4. Your Honour, Legislature has not provided for excluding the amount of export incentive from profits of the business while calculating deduction u/s 10B. The position is somewhat akin or close to Section

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

90. This is the formula which has been provided by sub section (4) for the purpose of working out the benefit or deduction under sub section. (1). 4. Your Honour, Legislature has not provided for excluding the amount of export incentive from profits of the business while calculating deduction u/s 10B. The position is somewhat akin or close to Section

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

90. This is the formula which has been provided by sub section (4) for the purpose of working out the benefit or deduction under sub section. (1). 4. Your Honour, Legislature has not provided for excluding the amount of export incentive from profits of the business while calculating deduction u/s 10B. The position is somewhat akin or close to Section

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

90,28,187 The DRP/TPO failed to appreciate that the medium transferred to pressure (MP) and low-pressure (LP) steam Paper unit transferred to the paper unit is metered. Therefore, (3=1-2) the reduction of units is contrary to the facts and circumstances of the case. This is clearly demonstrated by the snapshot provided at Page

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

2) of\nsection 75 of Customs Act requires the amount of draw back to be\ndetermined on a consideration of all the circumstances prevalent in a\nparticular trade and also based on the facts situation relevant in\nrespect of each of various classes of goods imported. Basically, the\nsource of duty draw back receipt lies in section 75 of Customs

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

SMT. SATYAWATI MARWAHA THROUGH LEGAL HEIR SH, CHANDER SHEIKHAR MARWAHA,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeal for Asstt

ITA 347/ASR/2024[2015-16]Status: DisposedITAT Amritsar30 Oct 2025AY 2015-16

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Ashray Sarna, C. A
Section 10(38)Section 132Section 144Section 144rSection 147Section 148Section 151Section 250(6)Section 68

90 Crores in the three-year span, which also ignored by the Ld. Assessing Officer and made huge addition without any basis. Sir, the Ld. Assessing Officer in para 2 of the impugned order it is stated that assessee made investment in M/s Dhanleela Investment & Trading Co. @ Rs. 7.30/- in F.Y 2012-13 and sold @ Rs. 204.80/- per share

SMT. SATYAWATI MARWAHA THROUGH LEGAL HEIR SH. CHANDER SHEIKHAR MARWAHA,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeal for Asstt

ITA 346/ASR/2024[2014-15]Status: DisposedITAT Amritsar30 Oct 2025AY 2014-15

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Ashray Sarna, C. A
Section 10(38)Section 132Section 144Section 144rSection 147Section 148Section 151Section 250(6)Section 68

90 Crores in the three-year span, which also ignored by the Ld. Assessing Officer and made huge addition without any basis. Sir, the Ld. Assessing Officer in para 2 of the impugned order it is stated that assessee made investment in M/s Dhanleela Investment & Trading Co. @ Rs. 7.30/- in F.Y 2012-13 and sold @ Rs. 204.80/- per share