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54 results for “transfer pricing”+ Section 127clear

Sorted by relevance

Delhi870Mumbai496Karnataka295Bangalore206Ahmedabad140Jaipur135Hyderabad107Chennai76Chandigarh74Kolkata73Cochin71Indore58Calcutta54Pune43Cuttack26Surat25Raipur21Lucknow17Rajkot16Visakhapatnam15SC13Jodhpur12Telangana11Agra11Nagpur10Varanasi5Rajasthan4A.K. SIKRI ROHINTON FALI NARIMAN3Amritsar3Allahabad2Jabalpur2Andhra Pradesh1

Key Topics

Section 343Section 36(1)3Section 93Section 36(2)2Section 260A2Section 22Section 422Addition to Income2

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

Section 32 of the Act 1961, held it to be a “license”. In the present set of facts the question of nomination or transfer of license is not involved. Even at the time of execution of the operating license agreement in question no amount was paid by ITC to ELEL as cost of acquisition of license. 19. M/S ELEL

PRINCIPAL COMMISSIONER OF INCOME TAX 2 KOLKATA vs. M/S DHUNSERI VENTURES LTD

Accordingly, the appeal fails and the same is dismissed

ITA/25/2024HC Calcutta20 Aug 2025

Bench: : The Hon'Ble The Chief Justice T.S Sivagnanam -A N D- Hon'Ble Justice Chaitali Chatterjee (Das) Date : 20Th August, 2025. Appearance : Mr. Tilak Mitra, Adv. Mr. Prithu Dudhorea, Adv. …For Appellant.

Section 1

Showing 1–20 of 54 · Page 1 of 3

Section 2
Section 2(8)
Section 260A
Section 42
Section 9

transfer of such goods or services is a specified domestic transaction referred to in section 92BA? b) WHETHER in facts of the case and in law, the Hon'ble ITAT is justified in not appreciating the finding of the TPO that the assessee's generating unit cannot as such claim any benefit under section 80IA of the Income

PRINCIPAL COMMISSIONER OF INCOME TAX, KOLKATA vs. M/S JJ EXPORTS PVT. LTD

The appeal stands disposed of on the ground that the company has been wound up and

ITAT/54/2018HC Calcutta05 Sept 2022

Bench: : The Hon’Ble Justice T.S. Sivagnanam & The Hon’Ble Justice Supratim Bhattacharya Date : September 5, 2022. Appearance: Ms. Smita Das De, Adv. … For Appellant Ms. Swapna Das, Adv. Mr. Siddhertha Das, Adv. …For Respondent Ga/1/2018(Ga/554/2018) The Court : We Have Heard Ms. Smita Das De, Learned Standing Counsel Appearing For The Appellant & Ms. Swapna Das & Mr. Siddhertha Das, Learned Advocates For The Respondent. There Is A Delay Of 127 Days In Filing This Appeal. We Have Perused The Affidavit Filed In Support Of The Application & We Find Sufficient Cause Has Not Been Shown To Prefer The Appeal Within The Period Of Limitation. Accordingly, The Application Is Allowed & The Delay In Filing The Appeal Is Condoned.

Section 260ASection 92C

127 days in filing this appeal. We have perused the affidavit filed in support of the application and we find sufficient cause has not been shown to prefer the appeal within the period of limitation. Accordingly, the application is allowed and the delay in filing the appeal is condoned. 2 ITAT/54/2018 This appeal filed by the revenue under Section 260A

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

PR CIT 9, KOLKATA vs. MANISHA TIKMANI

In the result, these appeals are allowed and the substantial

ITAT/155/2021HC Calcutta14 Jun 2022

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

Section 263 could not have been exercised and such power could have been exercised only when the assessing officer failed to conduct an enquiry which is not the case of the assessee before this Court. With regard to under what circumstances the power under Section 263 could be invoked and the parameters to be fulfilled, reliance was placed

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 263 could not have been exercised and such power could have been exercised only when the assessing officer failed to conduct an enquiry which is not the case of the assessee before this Court. With regard to under what circumstances the power under Section 263 could be invoked and the parameters to be fulfilled, reliance was placed

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 263 could not have been exercised and such power could have been exercised only when the assessing officer failed to conduct an enquiry which is not the case of the assessee before this Court. With regard to under what circumstances the power under Section 263 could be invoked and the parameters to be fulfilled, reliance was placed

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 263 could not have been exercised and such power could have been exercised only when the assessing officer failed to conduct an enquiry which is not the case of the assessee before this Court. With regard to under what circumstances the power under Section 263 could be invoked and the parameters to be fulfilled, reliance was placed

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 263 could not have been exercised and such power could have been exercised only when the assessing officer failed to conduct an enquiry which is not the case of the assessee before this Court. With regard to under what circumstances the power under Section 263 could be invoked and the parameters to be fulfilled, reliance was placed

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 263 could not have been exercised and such power could have been exercised only when the assessing officer failed to conduct an enquiry which is not the case of the assessee before this Court. With regard to under what circumstances the power under Section 263 could be invoked and the parameters to be fulfilled, reliance was placed

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 263 could not have been exercised and such power could have been exercised only when the assessing officer failed to conduct an enquiry which is not the case of the assessee before this Court. With regard to under what circumstances the power under Section 263 could be invoked and the parameters to be fulfilled, reliance was placed

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

In the result, these appeals are allowed and the substantial

ITAT/87/2021HC Calcutta14 Jun 2022

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

Section 263 could not have been exercised and such power could have been exercised only when the assessing officer failed to conduct an enquiry which is not the case of the assessee before this Court. With regard to under what circumstances the power under Section 263 could be invoked and the parameters to be fulfilled, reliance was placed

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 263 could not have been exercised and such power could have been exercised only when the assessing officer failed to conduct an enquiry which is not the case of the assessee before this Court. With regard to under what circumstances the power under Section 263 could be invoked and the parameters to be fulfilled, reliance was placed

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 263 could not have been exercised and such power could have been exercised only when the assessing officer failed to conduct an enquiry which is not the case of the assessee before this Court. With regard to under what circumstances the power under Section 263 could be invoked and the parameters to be fulfilled, reliance was placed

PRINCIPAL COMMISSIONER OF INCOME TAX, SILIGURI vs. PRAKASHO DEVI SARIA

In the result, these appeals are allowed and the substantial

ITAT/138/2021HC Calcutta14 Jun 2022

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

Section 263 could not have been exercised and such power could have been exercised only when the assessing officer failed to conduct an enquiry which is not the case of the assessee before this Court. With regard to under what circumstances the power under Section 263 could be invoked and the parameters to be fulfilled, reliance was placed

PRINCIPAL COMMISSIONER OF INCOME TAX-18, KOLKATA vs. SRI VIKASH GOEL

In the result, these appeals are allowed and the substantial

ITAT/85/2021HC Calcutta14 Jun 2022

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

Section 263 could not have been exercised and such power could have been exercised only when the assessing officer failed to conduct an enquiry which is not the case of the assessee before this Court. With regard to under what circumstances the power under Section 263 could be invoked and the parameters to be fulfilled, reliance was placed

PRINCIPAL COMMISSIONER OF INCOME TAX ,BURDWAN vs. BIJAYA TAH

In the result, these appeals are allowed and the substantial

ITAT/122/2021HC Calcutta14 Jun 2022

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

Section 263 could not have been exercised and such power could have been exercised only when the assessing officer failed to conduct an enquiry which is not the case of the assessee before this Court. With regard to under what circumstances the power under Section 263 could be invoked and the parameters to be fulfilled, reliance was placed

PRINCIPAL COMMISSIONER OF INCOME TAX -5,KOLKATA vs. SWATI BAJAJ

In the result, these appeals are allowed and the substantial

ITAT/6/2022HC Calcutta14 Jun 2022

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

Section 263 could not have been exercised and such power could have been exercised only when the assessing officer failed to conduct an enquiry which is not the case of the assessee before this Court. With regard to under what circumstances the power under Section 263 could be invoked and the parameters to be fulfilled, reliance was placed

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 263 could not have been exercised and such power could have been exercised only when the assessing officer failed to conduct an enquiry which is not the case of the assessee before this Court. With regard to under what circumstances the power under Section 263 could be invoked and the parameters to be fulfilled, reliance was placed

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 263 could not have been exercised and such power could have been exercised only when the assessing officer failed to conduct an enquiry which is not the case of the assessee before this Court. With regard to under what circumstances the power under Section 263 could be invoked and the parameters to be fulfilled, reliance was placed