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76 results for “transfer pricing”+ Section 2clear

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Key Topics

Section 260A22Section 15411Addition to Income10Section 143(3)9Section 409Section 144C9Transfer Pricing8Section 92B5Section 14A

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 (223 Taxman 234) (Chattisgarh HC) 2

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

Showing 1–20 of 76 · Page 1 of 4

5
Section 1955
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 (223 Taxman 234) (Chattisgarh HC) 2

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 (223 Taxman 234) (Chattisgarh HC) 2

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 -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

2 (47) of the Act, 1961. ii) The aforesaid transfer being transfer of a long term capital asset for Rs.32.42 crores resulted in a long term capital gain under Section 45 of the Act, 1961 and the respondent/assessee has paid long term capital gain tax. The Tribunal has not committed any manifest error of law to hold the transfer

PRINCIPAL COMMISSIONER OF INCOME TAX-3, KOLKATA vs. M/S. EIH LTD

ITAT/39/2020HC Calcutta17 Jan 2022

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

Section 14ASection 194HSection 195Section 2Section 2(47)Section 260ASection 40Section 50BSection 9(1)

price paid for or attributable to an asset exceeds the written down the value of the asset, proviso 2 to section 10(2)(vii) would ex facie be attracted. Where the person carrying on the business transfers

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. Along with the draft order, a notice of demand under Section 156 and a notice initiating penalty proceedings under Section 274 read with Section 270A were also issued. Being aggrieved by the proposed variation, the petitioner filed objections before the Dispute Resolution Panel within the time prescribed under Section 144C(2

PRINCIPAL COMMISSIONER OF INCOME TAX-2, KOLKATA vs. M/S. CENTURY ENKA LIMITED

ITA/7/2020HC Calcutta27 Feb 2023

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

2 companies and certain other individuals as Directors of 4 listed companies, 3 subsidiaries of one listed company and an unlisted company is bad in law since the Joint APLs merely represents the estate of PDB and thus, had no rights to seek appointment of Directors in companies in which PDB was not a "Member". Further, without prejudice

PRINCIPAL COMMISSIONER OF INCOME TAX-4, KOLKATA vs. M/S V2 RETAIL LTD.

ITAT/18/2020HC Calcutta28 Jul 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE BIVAS PATTANAYAK

2 companies and certain other individuals as Directors of 4 listed companies, 3 subsidiaries of one listed company and an unlisted company is bad in law since the Joint APLs merely represents the estate of PDB and thus, had no rights to seek appointment of Directors in companies in which PDB was not a "Member". Further, without prejudice

PRINCIPAL COMMISSIONER OF INCOME TAX-4, KOLKATA vs. M/S. JAGANNATH BANWARILAL TEXOFABS PVT LTD

ITAT/9/2020HC Calcutta27 Jul 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE BIVAS PATTANAYAK

2 companies and certain other individuals as Directors of 4 listed companies, 3 subsidiaries of one listed company and an unlisted company is bad in law since the Joint APLs merely represents the estate of PDB and thus, had no rights to seek appointment of Directors in companies in which PDB was not a "Member". Further, without prejudice

PRINCIPAL COMMISSIONER OF INCOME TAX-4, KOLKATA vs. M/S. J.J.EXPORTERS LTD.

ITAT/5/2020HC Calcutta26 Jul 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE BIVAS PATTANAYAK

2 companies and certain other individuals as Directors of 4 listed companies, 3 subsidiaries of one listed company and an unlisted company is bad in law since the Joint APLs merely represents the estate of PDB and thus, had no rights to seek appointment of Directors in companies in which PDB was not a "Member". Further, without prejudice

PRINCIPAL COMMISSIONER OF INCOME TAX-5, KOLKATA vs. L D S CITY PROJECTS PVT LTD

ITAT/3/2020HC Calcutta21 Jul 2022

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE BIVAS PATTANAYAK

2 companies and certain other individuals as Directors of 4 listed companies, 3 subsidiaries of one listed company and an unlisted company is bad in law since the Joint APLs merely represents the estate of PDB and thus, had no rights to seek appointment of Directors in companies in which PDB was not a "Member". Further, without prejudice

PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL-1), KOLKATA vs. M/S. RUNGTA MINES LTD

ITA/13/2020HC Calcutta08 Apr 2022

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

2 companies and certain other individuals as Directors of 4 listed companies, 3 subsidiaries of one listed company and an unlisted company is bad in law since the Joint APLs merely represents the estate of PDB and thus, had no rights to seek appointment of Directors in companies in which PDB was not a "Member". Further, without prejudice

PRINCIPAL COMMISSIONER OF INCOME TAX-4, KOLKATA vs. M/S. TCG LIFESCIENCES LTD.

ITAT/10/2020HC Calcutta08 Apr 2022

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

2 companies and certain other individuals as Directors of 4 listed companies, 3 subsidiaries of one listed company and an unlisted company is bad in law since the Joint APLs merely represents the estate of PDB and thus, had no rights to seek appointment of Directors in companies in which PDB was not a "Member". Further, without prejudice

PRINCIPAL COMMISSIONER OF INCOME TAX-2, KOLKATA vs. M/S THE CALCUTTA TRAMWAYS COMPANY (1978) LTD.

ITAT/20/2020HC Calcutta04 Mar 2022

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

2 companies and certain other individuals as Directors of 4 listed companies, 3 subsidiaries of one listed company and an unlisted company is bad in law since the Joint APLs merely represents the estate of PDB and thus, had no rights to seek appointment of Directors in companies in which PDB was not a "Member". Further, without prejudice

PRINCIPAL COMMISSIONER OF INCOME TAX-1, KOLKATA vs. M/S. HEIGHT INSURANCE SERVICES LTD

ITAT/4/2020HC Calcutta16 Dec 2021

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

2 companies and certain other individuals as Directors of 4 listed companies, 3 subsidiaries of one listed company and an unlisted company is bad in law since the Joint APLs merely represents the estate of PDB and thus, had no rights to seek appointment of Directors in companies in which PDB was not a "Member". Further, without prejudice

PRINCIPAL CIT-14, KOLKATA vs. SHRI VISHWANATH GUPTA

ITA/21/2020HC Calcutta07 Dec 2021

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

2 companies and certain other individuals as Directors of 4 listed companies, 3 subsidiaries of one listed company and an unlisted company is bad in law since the Joint APLs merely represents the estate of PDB and thus, had no rights to seek appointment of Directors in companies in which PDB was not a "Member". Further, without prejudice

RAJESH JAJODIA vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 45 KOLKATA AND ORS

ITAT/26/2020HC Calcutta27 Aug 2021

Bench: HON'BLE JUSTICE RAJESH BINDAL, CHIEF JUSTICE (ACTING),HON'BLE JUSTICE RAJARSHI BHARADWAJ

2 companies and certain other individuals as Directors of 4 listed companies, 3 subsidiaries of one listed company and an unlisted company is bad in law since the Joint APLs merely represents the estate of PDB and thus, had no rights to seek appointment of Directors in companies in which PDB was not a "Member". Further, without prejudice

M/S SINGHI AND CO vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX VIII

ITA/15/2020HC Calcutta27 Apr 2021

Bench: HON'BLE JUSTICE RAJESH BINDAL, CHIEF JUSTICE (ACTING),HON'BLE JUSTICE ANIRUDDHA ROY

2 companies and certain other individuals as Directors of 4 listed companies, 3 subsidiaries of one listed company and an unlisted company is bad in law since the Joint APLs merely represents the estate of PDB and thus, had no rights to seek appointment of Directors in companies in which PDB was not a "Member". Further, without prejudice

TCG LIFE SCIENCES PVT LTD vs. JOINT COMM OF INCOME TAX RANGE59 KOL AND ANR

ITA/26/2020HC Calcutta04 Mar 2021

Bench: HON'BLE JUSTICE RAJESH BINDAL, CHIEF JUSTICE (ACTING),HON'BLE JUSTICE ANIRUDDHA ROY

2 companies and certain other individuals as Directors of 4 listed companies, 3 subsidiaries of one listed company and an unlisted company is bad in law since the Joint APLs merely represents the estate of PDB and thus, had no rights to seek appointment of Directors in companies in which PDB was not a "Member". Further, without prejudice