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75 results for “transfer pricing”+ Section 1clear

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Key Topics

Section 260A20Section 15411Addition to Income10Section 409Section 143(3)8Transfer Pricing7Section 92B5Section 14A5Section 1955

PRINCIPAL COMMISSIONER OF INCOME TAX CENTRAL 1 KOLKATA vs. RUNGTA MINES LTD

In the result, these appeals are dismissed and the substantial

ITAT/217/2024HC Calcutta09 Jul 2025

Bench: THE HON'BLE THE CHIEF JUSTICE T.S SIVAGNANAM,HON'BLE JUSTICE CHAITALI CHATTERJEE (DAS)

Section 260ASection 80Section 80ASection 92BSection 92F

Section 80IA (8) of the Act. The CIT(A) noted that the assessee conducted a Transfer Pricing Study for the same which revealed that after undertaking FAR analysis, it was concluded that the CPPs were electricity providers to the manufacturing units bearing normal risk associated with the said activity and that the 1

PRINCIPAL COMMISSIONER OF INCOME TAX CENTRAL 1 KOLKATA vs. RUNGTA MINES LTD

Showing 1–20 of 75 · Page 1 of 4

Section 92C5
Disallowance5
Comparables/TP5

In the result, these appeals are dismissed and the substantial

ITAT/216/2024HC Calcutta09 Jul 2025

Bench: THE HON'BLE THE CHIEF JUSTICE T.S SIVAGNANAM,HON'BLE JUSTICE CHAITALI CHATTERJEE (DAS)

Section 260ASection 80Section 80ASection 92BSection 92F

Section 80IA (8) of the Act. The CIT(A) noted that the assessee conducted a Transfer Pricing Study for the same which revealed that after undertaking FAR analysis, it was concluded that the CPPs were electricity providers to the manufacturing units bearing normal risk associated with the said activity and that the 1

PRINCIPAL COMMISSIONER OF INCOME TAX CENTRAL 1 KOLKATA vs. RUNGTA MINES LTD

In the result, these appeals are dismissed and the substantial

ITAT/215/2024HC Calcutta09 Jul 2025

Bench: THE HON'BLE THE CHIEF JUSTICE T.S SIVAGNANAM,HON'BLE JUSTICE CHAITALI CHATTERJEE (DAS)

Section 260ASection 80Section 80ASection 92BSection 92F

Section 80IA (8) of the Act. The CIT(A) noted that the assessee conducted a Transfer Pricing Study for the same which revealed that after undertaking FAR analysis, it was concluded that the CPPs were electricity providers to the manufacturing units bearing normal risk associated with the said activity and that the 1

PRINCIPAL COMMISSIONER OF INCOME TAX 5 KOLKATA vs. PREMIER TIE UP PVT LTD

ITAT/81/2022HC Calcutta26 Sept 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE SUPRATIM BHATTACHARYA

For Respondent: Mr. Dhruba Ghosh, Adv
Section 34Section 36(1)Section 36(2)

price of the shares sold and transferred by the Bagri Group of respondents to BulakidasBhaiya and his nominees within a period of 7 days' from date of the handing over of the share scrips and properly executed transfer deeds by the sellers to the purchasers in terms of this final Award. h) All other claims by parties against each other

PRINCIPAL COMMISSIONER OF INCOME TAX 2 KOLKATA vs. DIGVIJAY VINIMAY PVT LTD

ITAT/284/2024HC Calcutta03 Jan 2025

Bench: THE HON'BLE THE CHIEF JUSTICE T.S SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

Section 115JSection 144CSection 144C(1)Section 144C(13)Section 144C(2)Section 144C(5)Section 153Section 156Section 270ASection 274

Transfer Pricing Officer under Section 92CA(1) of the Act for determination of the arm’s length price in relation

PRINCIPAL COMMISSIONER OF INCOME TAX -3, KOLKATA vs. M/S. ITC LIMITED

Appeal is allowed to the extent indicated

ITA/125/2018HC Calcutta27 Jun 2024

Bench: HON'BLE JUSTICE SURYA PRAKASH KESARWANI,HON'BLE JUSTICE RAJARSHI BHARADWAJ

price paid or promised. Under Section 108 of the said Act, the lessee is entitled to be put in possession of the property. A lease is therefore a transfer of an interest in land. The interest transferred is called the leasehold interest. The lessor parts with his right to enjoy the property during the term of the lease

PRINCIPAL COMMISSIONER OF INCOME TAX 1 KOLKATA vs. M/S ITC LTD

ITAT/89/2025HC Calcutta21 Jul 2025

Bench: The Learned Tribunal – One By The Assessee & The Other By The Revenue Which Have Been Disposed Of By A Common Order, Impugned In This Appeal. 2. The Revenue Has Raised The Following Substantial Questions Of Law For Consideration :

For Appellant: Mr. Prithu Dudhoria, AdvocateFor Respondent: Mr. J.P. Khaitan, Senior Advocate
Section 14ASection 260ASection 37(1)Section 40a

transfer pricing adjustment. Thereafter the assessing officer called for various details and the matter was discussed with the assessee. The issue which was considered by the assessing officer are with regard to the 6 unexpired discount on forward contracts, market to market loss of forward contracts, designed charges, non-deduction of TDS for information technology expense, information technology expense, patent

PRINCIPAL COMMISSIONER OF INCOME TAX-5, KOLKATA vs. JEMISH SHAH

In the result, these appeals are allowed and the substantial

ITAT/57/2021HC Calcutta14 Jun 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

Section 142 (1) of the Act. The assessee is stated to have produced the copy of the income tax returns, profit and loss account, ITAT NO. 06 OF 2022 AND ETC. BATCH Page 13 of 150 balance sheet, computation of total income, statement of STCG/LTCG, D- Mat account, contract notes, bank statements and other details. The assessing officer after scrutiny

PRINCIPAL COMMISSIONER OF INCOME TAX 9, KOLKATA vs. PUSPA DEVI TIKMANI

In the result, these appeals are allowed and the substantial

ITAT/150/2021HC Calcutta14 Jun 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

Section 142 (1) of the Act. The assessee is stated to have produced the copy of the income tax returns, profit and loss account, ITAT NO. 06 OF 2022 AND ETC. BATCH Page 13 of 150 balance sheet, computation of total income, statement of STCG/LTCG, D- Mat account, contract notes, bank statements and other details. The assessing officer after scrutiny

PRINCIPAL COMMISSIONER OF INCOME TAX ASANSOL KOLKATA vs. RAJESH JHUNJHUNWALA

In the result, these appeals are allowed and the substantial

ITAT/26/2021HC Calcutta14 Jun 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

Section 142 (1) of the Act. The assessee is stated to have produced the copy of the income tax returns, profit and loss account, ITAT NO. 06 OF 2022 AND ETC. BATCH Page 13 of 150 balance sheet, computation of total income, statement of STCG/LTCG, D- Mat account, contract notes, bank statements and other details. The assessing officer after scrutiny

PRINCIPAL COMMISSIONER OF INCOME TAX-5, KOLKATA vs. AAYUSH JHUNJHUNWALA

In the result, these appeals are allowed and the substantial

ITAT/88/2021HC Calcutta14 Jun 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

Section 142 (1) of the Act. The assessee is stated to have produced the copy of the income tax returns, profit and loss account, ITAT NO. 06 OF 2022 AND ETC. BATCH Page 13 of 150 balance sheet, computation of total income, statement of STCG/LTCG, D- Mat account, contract notes, bank statements and other details. The assessing officer after scrutiny

PRINCIPAL COMMISSIONER OF INCOME TAX ASANSOL KOLKATA vs. RAKESH JHUNJHUNWALA

In the result, these appeals are allowed and the substantial

ITAT/27/2021HC Calcutta14 Jun 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

Section 142 (1) of the Act. The assessee is stated to have produced the copy of the income tax returns, profit and loss account, ITAT NO. 06 OF 2022 AND ETC. BATCH Page 13 of 150 balance sheet, computation of total income, statement of STCG/LTCG, D- Mat account, contract notes, bank statements and other details. The assessing officer after scrutiny

PRINCIPAL COMMISSIONER OF INCOME TAX-SILIGURI vs. SHEKHAR AGARWAL

In the result, these appeals are allowed and the substantial

ITAT/139/2021HC Calcutta14 Jun 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

Section 142 (1) of the Act. The assessee is stated to have produced the copy of the income tax returns, profit and loss account, ITAT NO. 06 OF 2022 AND ETC. BATCH Page 13 of 150 balance sheet, computation of total income, statement of STCG/LTCG, D- Mat account, contract notes, bank statements and other details. The assessing officer after scrutiny

PRINCIPAL COMMISSIONER OF INCOME TAX, CENTRAL-1, KOLKATA vs. KRISHNA KUMAR PARSURAMKA

In the result, these appeals are allowed and the substantial

ITAT/130/2021HC Calcutta14 Jun 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

Section 142 (1) of the Act. The assessee is stated to have produced the copy of the income tax returns, profit and loss account, ITAT NO. 06 OF 2022 AND ETC. BATCH Page 13 of 150 balance sheet, computation of total income, statement of STCG/LTCG, D- Mat account, contract notes, bank statements and other details. The assessing officer after scrutiny

PRINCIPAL COMMISSIONER OF INCOME TAX CENTRAL -1, KOLKATA vs. SURAJ SAHANA

In the result, these appeals are allowed and the substantial

ITAT/41/2020HC Calcutta14 Jun 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

Section 142 (1) of the Act. The assessee is stated to have produced the copy of the income tax returns, profit and loss account, ITAT NO. 06 OF 2022 AND ETC. BATCH Page 13 of 150 balance sheet, computation of total income, statement of STCG/LTCG, D- Mat account, contract notes, bank statements and other details. The assessing officer after scrutiny

PRINCIPAL COMMISSIONER OF INCOME TAX-9, KOLKATA vs. GITESH TIKMANI

In the result, these appeals are allowed and the substantial

ITAT/154/2021HC Calcutta14 Jun 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

Section 142 (1) of the Act. The assessee is stated to have produced the copy of the income tax returns, profit and loss account, ITAT NO. 06 OF 2022 AND ETC. BATCH Page 13 of 150 balance sheet, computation of total income, statement of STCG/LTCG, D- Mat account, contract notes, bank statements and other details. The assessing officer after scrutiny

PRINCIPAL COMMISSIONER OF INCOME TAX, SILIGURI vs. SRI SATYA NARAYAN SARIA

In the result, these appeals are allowed and the substantial

ITAT/168/2021HC Calcutta14 Jun 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

Section 142 (1) of the Act. The assessee is stated to have produced the copy of the income tax returns, profit and loss account, ITAT NO. 06 OF 2022 AND ETC. BATCH Page 13 of 150 balance sheet, computation of total income, statement of STCG/LTCG, D- Mat account, contract notes, bank statements and other details. The assessing officer after scrutiny

PRINCIPAL COMMISSIONER OF INCOME TAX vs. MUKESH SARAOGI (HUF)

In the result, these appeals are allowed and the substantial

ITAT/76/2021HC Calcutta14 Jun 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

Section 142 (1) of the Act. The assessee is stated to have produced the copy of the income tax returns, profit and loss account, ITAT NO. 06 OF 2022 AND ETC. BATCH Page 13 of 150 balance sheet, computation of total income, statement of STCG/LTCG, D- Mat account, contract notes, bank statements and other details. The assessing officer after scrutiny

PRINCIPAL COMMISSIONER OF INCOME TAX-15, KOLKATA vs. SMT. BABITA AGARWAL

In the result, these appeals are allowed and the substantial

ITAT/64/2020HC Calcutta14 Jun 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

Section 142 (1) of the Act. The assessee is stated to have produced the copy of the income tax returns, profit and loss account, ITAT NO. 06 OF 2022 AND ETC. BATCH Page 13 of 150 balance sheet, computation of total income, statement of STCG/LTCG, D- Mat account, contract notes, bank statements and other details. The assessing officer after scrutiny

PRINCIPAL COMMISSIONER OF INCOME TAX-12, KOLKATA vs. MUKTA AGARWAL

In the result, these appeals are allowed and the substantial

ITAT/44/2020HC Calcutta14 Jun 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

Section 142 (1) of the Act. The assessee is stated to have produced the copy of the income tax returns, profit and loss account, ITAT NO. 06 OF 2022 AND ETC. BATCH Page 13 of 150 balance sheet, computation of total income, statement of STCG/LTCG, D- Mat account, contract notes, bank statements and other details. The assessing officer after scrutiny