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64 results for “transfer pricing”+ Section 69Aclear

Sorted by relevance

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Key Topics

Addition to Income45Section 143(3)33Section 153C30Section 153A30Section 13227Section 132(4)26Section 69A19Section 115B19Section 25016Cash Deposit

SRI. D. K SHIVAKUMAR ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BENGALURU

ITA 1064/BANG/2024[2018-19]Status: DisposedITAT Bangalore21 Feb 2025AY 2018-19

Bench: Shri Laxmi Prasad Sahu & Shri Soundarajan Kassessment Year : 2018-19

For Appellant: S/ShriFor Respondent: Shri.Y. V. Raviraj, Sr. Standing Counsel
Section 132(4)Section 143(2)Section 250Section 292CSection 69ASection 69B

69A of the Act is unsustainable in law. The addition is made on unsubstantiated entries in some loose sheets and does not represent any money found and hence does not come under the purview of Section 69A of the Act.The addition is made out on basis of loose sheets of documents, which does not come under the ambit of ‘books

Showing 1–20 of 64 · Page 1 of 4

10
Natural Justice7
Demonetization5

M/S. TOYOTA TAUSHO INDIA PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -3(1)(1), BENGALURU

Accordingly, this ground is allowed for statistical purposes

ITA 2806/BANG/2017[2013-14]Status: DisposedITAT Bangalore02 Mar 2023AY 2013-14

Bench: Shri N.V Vasudevan & Shri Laxmi Prasad Sahu

For Appellant: Shri Darpan Kirpalani, AdvocateFor Respondent: Shri Sunil Kumar Singh, CIT (D.R)
Section 143(3)Section 92C(2)

transfer pricing adjustment should be restricted only to the AE related transactions of the assessee.” 11.3 Respectfully following the above judgment of coordinate bench of the Tribunal, we allow this ground of the assessee. Ground No.8 12. The ld.AR of the assessee submitted that Rohan Motors Ltd., and Sicagen India Ltd., were considered by the TPO as comparable companies after

M/S. MUKKA PROTENIS LIMITED,MANGALURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX, CENTRAL, BANGALORE

In the result, the appeal filed by the assessee stands dismissed

ITA 433/BANG/2022[2018-19]Status: DisposedITAT Bangalore17 Nov 2022AY 2018-19
For Appellant: Shri V. Srinivasan, Advocate
Section 115BSection 143Section 153DSection 263Section 69C

Transfer Pricing Officer" shall have the same meaning as assigned to it in the Explanation to section 92CA. Page 13 (2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed. (3) Notwithstanding anything contained in sub-section

SMT. MALAPUR MOUNIKA,CHITRADURGA vs. INCOME-TAX OFFICER, WARD-1, CHITRADURGA

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 599/BANG/2023[2017-18]Status: DisposedITAT Bangalore30 Oct 2023AY 2017-18

Bench: Shri George George Kassessment Year : 2017-18 Smt. Malapur Mounika, Vs. Ito, Prop : M/S. Kaligal Poultry Services, Ward – 1, M H Road, Chitradurga. Chitradurga – 577 501. Pan : Bhypm 5247 F Appellant Respondent Assessee By : Ms. Sunaina Bhatia, Ca Revenue By : Shri. Ganesh R Ghale, Advocate, Standing Counsel For Revenue. Date Of Hearing : 27.10.2023 Date Of Pronouncement : 30.10.2023

For Appellant: Ms. Sunaina Bhatia, CAFor Respondent: Shri. Ganesh R Ghale, Advocate, Standing Counsel for Revenue
Section 115BSection 15BSection 234Section 250Section 69A

transferring or receiving SBNs is only after the ‘appointed day’ which is 31.12.2016. In view of the above, there is no violation by the assessee of any law in accepting SBNs for the purpose of cash sales and considering it to be a due discharge of debt. Furthermore, even the CBDT had issued various Standard Operating Procedures (SOPs) instructing

ASSISTANT COMMISSIONER OF INCOME TAX (E) CIRCLE-1 , BANGALORE vs. KARNATAKA INDUSTRIAL AREA DEVELOPMENT BOARD , BANGALORE

In the result appeal filed by assessee stands allowed as indicated hereinabove

ITA 951/BANG/2017[2012-13]Status: DisposedITAT Bangalore03 Jul 2020AY 2012-13

Bench: Shri. B. R. Baskaran & Smt. Beena Pillaiassessment Year : 2012 – 13

For Appellant: Ms. Neera Malhotra, CIT (DR)For Respondent: Shri Padamchand Khincha, CA
Section 11Section 13(8)Section 2(15)Section 43B

69A without proper appreciation of the explanation offered by the appellant is bad in law and should be deleted. 10. The Hon'ble Commissioner of Income tax (Appeals) - 14, Bangalore has erred in confirming the levy of interest under section 234A, 234B and 234D of the Act. On facts and circumstances of the case and law applicable, interest under section

M/S. MAHAVEERA MINORITY CREDIT CO-OPERATIVE SOCIETY LIMITED,VIJAYANAGAR vs. INCOME TAX OFFICER, WARD-1 & TPS , HOSPET

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 528/BANG/2024[2017-18]Status: DisposedITAT Bangalore13 Jun 2024AY 2017-18
Section 115BSection 143(3)Section 250Section 68

price in SBNs as a part of such activity,\nif accepted, would defeat the provisions of such section of RBI, 1934 and it\nleads to public policy. Therefore, the activity of society with regard to this,\nis ab-initio void as per the relevant provisions. Hence the society for having\ndeposited such SBNs in banks during such period, represents

KAMAL KOTHARI ,CHANNAPATNA vs. INCOME TAX OFFICER, WARD-1, , RAMNAGAR

In the result, appeal filed by the assessee is allowed

ITA 741/BANG/2023[2017-18]Status: DisposedITAT Bangalore23 Nov 2023AY 2017-18

Bench: Shri George George Kassessment Year : 2017-18 Shri. Kamal Kothari, Vs. Ito, Prop: M/S. B. L. Bankers, Ward – 1, M. G. Road, Ramnagar. Channapatna – 562 160. Pan : Bcgpk 1898 B Appellant Respondent Assessee By : Smt. Suman Lunkar, Ca Revenue By : Shri. Ganesh R Ghale, Advocate, Standing Counsel For Revenue. Date Of Hearing : 21.11.2023 Date Of Pronouncement : 23.11.2023

For Appellant: Smt. Suman Lunkar, CAFor Respondent: Shri. Ganesh R Ghale, Advocate, Standing Counsel for Revenue
Section 115BSection 234BSection 250Section 69A

transfer, as he had done by depositing cash of Rs.20,000/-. This again goes on to prove that the assessee had no such cash on hand. f) Lastly, If the assessee had cash on hand on the day of demonetization day le.. 8.11.2016 and from 9.11.2016. one would have exchanged the old notes only through bank deposits

SRI. B.V. RAVIKUMAR,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-6(3)(1), BENGALURU

ITA 138/BANG/2022[2015-16]Status: DisposedITAT Bangalore28 Nov 2022AY 2015-16

Bench: Smt. Beena Pillai & Ms. Padmavathy S

For Appellant: Shri V. Chandrashekar, AdvocateFor Respondent: Smt. Priyadarshini Besaganni, Addl.CIT(DR)(ITAT)
Section 143(3)Section 148Section 153A

prices dip, materials could be ITA Nos.137 & 138/B/2022 Page 5 of 31 immediately bought and also to give advances to vendors. When the vendors short supply and refund the money the cash was re-deposited into the bank account. The assessee further submitted that certain money was withdrawn towards purchase of agricultural land and when the transaction

SMT. K.R. GEETHA,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 6(3)(1), BENGALURU

ITA 2305/BANG/2019[2014-15]Status: DisposedITAT Bangalore28 Nov 2022AY 2014-15

Bench: Smt. Beena Pillai & Ms. Padmavathy S

For Appellant: Shri V. Chandrashekar, AdvocateFor Respondent: Smt. Priyadarshini Besaganni, Addl.CIT(DR)(ITAT)
Section 143(3)Section 148Section 153A

prices dip, materials could be ITA Nos.137 & 138/B/2022 Page 5 of 31 immediately bought and also to give advances to vendors. When the vendors short supply and refund the money the cash was re-deposited into the bank account. The assessee further submitted that certain money was withdrawn towards purchase of agricultural land and when the transaction

SRI. B.V. RAVIKUMAR,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-6(3)(1), BANGALORE

ITA 137/BANG/2022[2014-15]Status: DisposedITAT Bangalore28 Nov 2022AY 2014-15

Bench: Smt. Beena Pillai & Ms. Padmavathy S

For Appellant: Shri V. Chandrashekar, AdvocateFor Respondent: Smt. Priyadarshini Besaganni, Addl.CIT(DR)(ITAT)
Section 143(3)Section 148Section 153A

prices dip, materials could be ITA Nos.137 & 138/B/2022 Page 5 of 31 immediately bought and also to give advances to vendors. When the vendors short supply and refund the money the cash was re-deposited into the bank account. The assessee further submitted that certain money was withdrawn towards purchase of agricultural land and when the transaction

SMT. K.R. GEETHA,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 6(3)(1), BENGALURU

ITA 2306/BANG/2019[2015-16]Status: DisposedITAT Bangalore28 Nov 2022AY 2015-16

Bench: Smt. Beena Pillai & Ms. Padmavathy S

For Appellant: Shri V. Chandrashekar, AdvocateFor Respondent: Smt. Priyadarshini Besaganni, Addl.CIT(DR)(ITAT)
Section 143(3)Section 148Section 153A

prices dip, materials could be ITA Nos.137 & 138/B/2022 Page 5 of 31 immediately bought and also to give advances to vendors. When the vendors short supply and refund the money the cash was re-deposited into the bank account. The assessee further submitted that certain money was withdrawn towards purchase of agricultural land and when the transaction

SRI RATHAN BABULAL LATH,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), BANGALORE

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 157/BANG/2020[2009-10]Status: DisposedITAT Bangalore05 Aug 2022AY 2009-10

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2009-10

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Shri Vilas V. Shinde, D.R
Section 132Section 153A

69A, apart from ownership of the asset/valuable article, which is deemed to be the income of the assessee for that financial year; it is also a pre-requisite that such asset/valuable article 'is not recorded in the books of accounts' maintained by the assessee (if any). In the instant case, even if the department's factual allegations were assumed

SHREE HANUMAN CREDIT SOUHARD SAHAKARI LIMITED,CHIKODI vs. PR. COMMISSIONER OF INCOME-TAX, HUBLI

In the result, the appeal of the assessee is allowed

ITA 29/BANG/2023[2017-18]Status: DisposedITAT Bangalore17 Mar 2023AY 2017-18

Bench: Smt. Beena Pillai & Ms. Padmavathy Sassessment Year : 2017-18

For Appellant: Shri S.V. Ravishankar, AdvocateFor Respondent: Shri D.K. Mishra, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 263Section 80P

69A read with section 115BBE. 3. When the case was selected for scrutiny specifically for examining high value receipt of cash shown from third parties in response data and cash deposited during the demonetization period, apart from other issues, it was necessary for the Assessing Officer to examine the source of cash and SBNs deposited and carry out necessary investigation

MR. ISHAAN HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOMER TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

ITA 1456/BANG/2024[2015-16]Status: DisposedITAT Bangalore16 Jul 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. LATE SHRI V G SIDDHARTHA, REPRESENTED BY LEGAL HEIR MS. MALVIKA HEGDE, BENGALURU

In the result the appeal filed by the revenue is hereby dismissed

ITA 2129/BANG/2024[2015-16]Status: DisposedITAT Bangalore16 Jul 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books

MR. ISHAAN HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOMER TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

ITA 1457/BANG/2024[2016-17]Status: DisposedITAT Bangalore16 Jul 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books

MRS. MALAVIKA HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

ITA 1447/BANG/2024[2018-19]Status: DisposedITAT Bangalore16 Jul 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. LATE SHRI V G SIDDHARTHA, REPRESENTED BY LEGAL HEIR MS. MALVIKA HEGDE, BENGALURU

In the result the appeal filed by the revenue is hereby dismissed

ITA 2130/BANG/2024[2016-17]Status: DisposedITAT Bangalore16 Jul 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books

MRS. MALAVIKA HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

ITA 1444/BANG/2024[2015-16]Status: DisposedITAT Bangalore16 Jul 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books

MR. AMARTHYA SIDDHARTHA L/R OF LATE SRI. V G . SIDDHARTHA ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

ITA 1448/BANG/2024[2013-14]Status: DisposedITAT Bangalore16 Jul 2025AY 2013-14

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri C Ramesh, CAFor Respondent: Ms. Neha Sahay, JCIT (DR)
Section 132Section 143(3)Section 153A

price of the same was for ₹3 crores only. This fact was duly explained by late Shri V G Siddhartha in the subsequent statement recorded under section 131 of the Act while explaining the excel sheet found from one Shri Sadananda Pujary. Thus, the sale consideration for this land was ₹3 crores, was accounted for in the books