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61 results for “transfer pricing”+ Section 43(5)clear

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Key Topics

Section 260A8Section 143(3)5Section 403Section 343Section 36(1)3Section 733Section 433Section 80A3Addition to Income3

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

THE COMMISSIONER OF INCOME TAX, KOLKATA -II, KOLKATA vs. M/S. MADANLAL LIMITED

ITA/51/2013HC Calcutta28 Jul 2025

: The Hon'Ble The Chief Justice T.S Sivagnanam -A N D- Hon'Ble Justice Chaitali Chatterjee (Das) Date : 28Th July, 2025. Appearance : Mr. Aryak Dutt, Adv. Mr. Prithu Dudhoria, Adv. …For Appellant.

Showing 1–20 of 61 · Page 1 of 4

Transfer Pricing3
Comparables/TP3
Long Term Capital Gains2
Bench:
Section 260ASection 28Section 43Section 43(5)Section 73Section 73(4)

Section 43, which in so far as material for our purposes, is as follows:- (5) "speculative transaction" means a transaction in which a contract for the purchase or sale of any commodity, including stocks and shares, is periodically or ultimately settled otherwise than by the actual delivery or transfer of the commodity or scrips: Provided that for the purposes

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

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

43,99,430/-. The case was selected for scrutiny and notice under Section 143(2) was issued and subsequently notice under Section 142(1) along with questionnaire was served on the assessee. Thereafter another notice under Section 142(1) was issued giving opportunity of hearing to the assessee. It is not in dispute that the assessee responded to the notice

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

43,99,430/-. The case was selected for scrutiny and notice under Section 143(2) was issued and subsequently notice under Section 142(1) along with questionnaire was served on the assessee. Thereafter another notice under Section 142(1) was issued giving opportunity of hearing to the assessee. It is not in dispute that the assessee responded to the notice

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

43,99,430/-. The case was selected for scrutiny and notice under Section 143(2) was issued and subsequently notice under Section 142(1) along with questionnaire was served on the assessee. Thereafter another notice under Section 142(1) was issued giving opportunity of hearing to the assessee. It is not in dispute that the assessee responded to the notice

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 143(3) of the Income Tax Act, 1961 (hereinafter Page 5 of 77 referred to as ‘the Act, 1961’) relating to the assessment year 2006-07. 6. In appeal filed by the respondent ITC before the CIT[Appeal], the appeal was allowed and the receipt of the aforesaid amount of Rs.32.42 crores was held to be a capital receipt

PRINCIPAL COMM OF INCOME TAX -4, KOLKATA vs. M/S LINDE INDIA LIMITED

ITAT/338/2016HC Calcutta05 Sept 2022

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

For Respondent: Mr. J. P. Khaitan, Sr. Adv
Section 143(3)Section 154Section 195Section 260ASection 40Section 5Section 50CSection 9

transfer of title to the goods outside India and hence there is no income chargeable to tax in India and therefore the provisions of Section 195 of the Act are not attracted. It was also contended that such advances to suppliers have also not been charged to Profit and loss Account for the relevant assessment year. 4. The Assessing Officer

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

Section 178 of the Companies Act, 2013. Therefore, the Chairman of the company, HVL cannot arrogate unto himself the power to cause such appointment when such power ultimately rests with the Board of Directors. The observation of the two Joint APLs that the evident performance of BCrL, the flagship company of MP Birla Group is deteriorating ever since, HVL became

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

Section 178 of the Companies Act, 2013. Therefore, the Chairman of the company, HVL cannot arrogate unto himself the power to cause such appointment when such power ultimately rests with the Board of Directors. The observation of the two Joint APLs that the evident performance of BCrL, the flagship company of MP Birla Group is deteriorating ever since, HVL became

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

Section 178 of the Companies Act, 2013. Therefore, the Chairman of the company, HVL cannot arrogate unto himself the power to cause such appointment when such power ultimately rests with the Board of Directors. The observation of the two Joint APLs that the evident performance of BCrL, the flagship company of MP Birla Group is deteriorating ever since, HVL became

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

Section 178 of the Companies Act, 2013. Therefore, the Chairman of the company, HVL cannot arrogate unto himself the power to cause such appointment when such power ultimately rests with the Board of Directors. The observation of the two Joint APLs that the evident performance of BCrL, the flagship company of MP Birla Group is deteriorating ever since, HVL became

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

Section 178 of the Companies Act, 2013. Therefore, the Chairman of the company, HVL cannot arrogate unto himself the power to cause such appointment when such power ultimately rests with the Board of Directors. The observation of the two Joint APLs that the evident performance of BCrL, the flagship company of MP Birla Group is deteriorating ever since, HVL became

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

Section 178 of the Companies Act, 2013. Therefore, the Chairman of the company, HVL cannot arrogate unto himself the power to cause such appointment when such power ultimately rests with the Board of Directors. The observation of the two Joint APLs that the evident performance of BCrL, the flagship company of MP Birla Group is deteriorating ever since, HVL became

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

Section 178 of the Companies Act, 2013. Therefore, the Chairman of the company, HVL cannot arrogate unto himself the power to cause such appointment when such power ultimately rests with the Board of Directors. The observation of the two Joint APLs that the evident performance of BCrL, the flagship company of MP Birla Group is deteriorating ever since, HVL became

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

Section 178 of the Companies Act, 2013. Therefore, the Chairman of the company, HVL cannot arrogate unto himself the power to cause such appointment when such power ultimately rests with the Board of Directors. The observation of the two Joint APLs that the evident performance of BCrL, the flagship company of MP Birla Group is deteriorating ever since, HVL became

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

Section 178 of the Companies Act, 2013. Therefore, the Chairman of the company, HVL cannot arrogate unto himself the power to cause such appointment when such power ultimately rests with the Board of Directors. The observation of the two Joint APLs that the evident performance of BCrL, the flagship company of MP Birla Group is deteriorating ever since, HVL became

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

Section 178 of the Companies Act, 2013. Therefore, the Chairman of the company, HVL cannot arrogate unto himself the power to cause such appointment when such power ultimately rests with the Board of Directors. The observation of the two Joint APLs that the evident performance of BCrL, the flagship company of MP Birla Group is deteriorating ever since, HVL became

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

Section 178 of the Companies Act, 2013. Therefore, the Chairman of the company, HVL cannot arrogate unto himself the power to cause such appointment when such power ultimately rests with the Board of Directors. The observation of the two Joint APLs that the evident performance of BCrL, the flagship company of MP Birla Group is deteriorating ever since, HVL became

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

Section 178 of the Companies Act, 2013. Therefore, the Chairman of the company, HVL cannot arrogate unto himself the power to cause such appointment when such power ultimately rests with the Board of Directors. The observation of the two Joint APLs that the evident performance of BCrL, the flagship company of MP Birla Group is deteriorating ever since, HVL became

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

Section 178 of the Companies Act, 2013. Therefore, the Chairman of the company, HVL cannot arrogate unto himself the power to cause such appointment when such power ultimately rests with the Board of Directors. The observation of the two Joint APLs that the evident performance of BCrL, the flagship company of MP Birla Group is deteriorating ever since, HVL became