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57 results for “transfer pricing”+ Section 45(3)clear

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Key Topics

Section 406Section 9(1)3Section 1953Section 343Section 36(1)3Section 260A2Section 45(3)2Section 1472Addition to Income2

PRINCIPAL COMMISSIONER OF INCOME TAX 1 KOLKATA vs. M/S ORCHID GRIHA NIRMAN PVT LTD

ITAT/108/2021HC Calcutta31 Jan 2022

Bench: : The Hon’Ble Justice T.S. Sivagnanam A N D The Hon’Ble Justice Hiranmay Bhattacharyya Dated January 31, 2022. [Via Video Conference] Appearance : Mr. P.K. Bhowmick, Adv. Mr. Asok Bhowmick, Adv. … For The Appellant Mr. J.P. Khaitan, Sr. Adv. Ms. Swapna Das, Adv. Mr. Siddharth Das, Adv. ..For The Respondent The Court :- We Have Heard Mr. P.K. Bhowmick, Learned Standing Counsel For The Appellant/Revenue Duly Assisted By Mr. Asok

Section 10Section 147Section 263ASection 45(3)

Section 45(3) does not seek to substitute by any other figure the value agreed between the partners at which the asset is transferred by a partner to the firm. 16. With regard to the revaluation, tribunal re-appreciated the facts which were considered by the CITA. With regard to the development of the area in question

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

Appeal is allowed to the extent indicated

Showing 1–20 of 57 · Page 1 of 3

ITA/125/2018HC Calcutta27 Jun 2024

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

45, the amount chargeable to income-tax as income of such specified entity under that sub-section which is attributable to the capital asset being transferred by the specified entity, calculated in the prescribed manner:] Provided ………: Provided ……… Provided ………. Provided ………. Provided ………. Provided ………. Provided ………. [Explanation. - For the purposes of this section,- (i)"foreign currency……….; (ii)the conversion of Indian currency into foreign

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

3 Joint APLs and such inventory was made pursuant to the order of the Hon'ble Division Bench dated 23rd August, 2012. Further, the Hon'ble Division Bench in the order dated 4th May, 2020 held that the unanimous report of Joint ALPs has not been disputed. Further, the inventory of assets records the share holding held by the estate

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

3 Joint APLs and such inventory was made pursuant to the order of the Hon'ble Division Bench dated 23rd August, 2012. Further, the Hon'ble Division Bench in the order dated 4th May, 2020 held that the unanimous report of Joint ALPs has not been disputed. Further, the inventory of assets records the share holding held by the estate

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

3 Joint APLs and such inventory was made pursuant to the order of the Hon'ble Division Bench dated 23rd August, 2012. Further, the Hon'ble Division Bench in the order dated 4th May, 2020 held that the unanimous report of Joint ALPs has not been disputed. Further, the inventory of assets records the share holding held by the estate

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

3 Joint APLs and such inventory was made pursuant to the order of the Hon'ble Division Bench dated 23rd August, 2012. Further, the Hon'ble Division Bench in the order dated 4th May, 2020 held that the unanimous report of Joint ALPs has not been disputed. Further, the inventory of assets records the share holding held by the estate

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

3 Joint APLs and such inventory was made pursuant to the order of the Hon'ble Division Bench dated 23rd August, 2012. Further, the Hon'ble Division Bench in the order dated 4th May, 2020 held that the unanimous report of Joint ALPs has not been disputed. Further, the inventory of assets records the share holding held by the estate

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

3 Joint APLs and such inventory was made pursuant to the order of the Hon'ble Division Bench dated 23rd August, 2012. Further, the Hon'ble Division Bench in the order dated 4th May, 2020 held that the unanimous report of Joint ALPs has not been disputed. Further, the inventory of assets records the share holding held by the estate

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

3 Joint APLs and such inventory was made pursuant to the order of the Hon'ble Division Bench dated 23rd August, 2012. Further, the Hon'ble Division Bench in the order dated 4th May, 2020 held that the unanimous report of Joint ALPs has not been disputed. Further, the inventory of assets records the share holding held by the estate

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

3 Joint APLs and such inventory was made pursuant to the order of the Hon'ble Division Bench dated 23rd August, 2012. Further, the Hon'ble Division Bench in the order dated 4th May, 2020 held that the unanimous report of Joint ALPs has not been disputed. Further, the inventory of assets records the share holding held by the estate

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

3 Joint APLs and such inventory was made pursuant to the order of the Hon'ble Division Bench dated 23rd August, 2012. Further, the Hon'ble Division Bench in the order dated 4th May, 2020 held that the unanimous report of Joint ALPs has not been disputed. Further, the inventory of assets records the share holding held by the estate

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

3 Joint APLs and such inventory was made pursuant to the order of the Hon'ble Division Bench dated 23rd August, 2012. Further, the Hon'ble Division Bench in the order dated 4th May, 2020 held that the unanimous report of Joint ALPs has not been disputed. Further, the inventory of assets records the share holding held by the estate

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

3 Joint APLs and such inventory was made pursuant to the order of the Hon'ble Division Bench dated 23rd August, 2012. Further, the Hon'ble Division Bench in the order dated 4th May, 2020 held that the unanimous report of Joint ALPs has not been disputed. Further, the inventory of assets records the share holding held by the estate

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

3 Joint APLs and such inventory was made pursuant to the order of the Hon'ble Division Bench dated 23rd August, 2012. Further, the Hon'ble Division Bench in the order dated 4th May, 2020 held that the unanimous report of Joint ALPs has not been disputed. Further, the inventory of assets records the share holding held by the estate

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

3 Joint APLs and such inventory was made pursuant to the order of the Hon'ble Division Bench dated 23rd August, 2012. Further, the Hon'ble Division Bench in the order dated 4th May, 2020 held that the unanimous report of Joint ALPs has not been disputed. Further, the inventory of assets records the share holding held by the estate

PRINCIPAL COMMISSIONER OF INCOME TAX-2, KOLKATA vs. M/S KESORAM INDUSTRIES LTD.

ITAT/17/2020HC Calcutta13 Jan 2021

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

3 Joint APLs and such inventory was made pursuant to the order of the Hon'ble Division Bench dated 23rd August, 2012. Further, the Hon'ble Division Bench in the order dated 4th May, 2020 held that the unanimous report of Joint ALPs has not been disputed. Further, the inventory of assets records the share holding held by the estate

SHWETA CHHAWCHHARIA vs. COMMISSIONER OF INCOME TAX, KOLKATA-12

ITAT/15/2020HC Calcutta21 Dec 2020

Bench: HON'BLE JUSTICE I. P. MUKERJI,HON'BLE JUSTICE KAUSIK CHANDA

3 Joint APLs and such inventory was made pursuant to the order of the Hon'ble Division Bench dated 23rd August, 2012. Further, the Hon'ble Division Bench in the order dated 4th May, 2020 held that the unanimous report of Joint ALPs has not been disputed. Further, the inventory of assets records the share holding held by the estate

PRINCIPAL COMMISSIONER OF INCOME TAX, CENTRAL-2, KOLKATA vs. ELECTROCAST SALES INDIA LTD.

ITAT/11/2020HC Calcutta18 Dec 2020

Bench: HON'BLE JUSTICE I. P. MUKERJI,HON'BLE JUSTICE KAUSIK CHANDA

3 Joint APLs and such inventory was made pursuant to the order of the Hon'ble Division Bench dated 23rd August, 2012. Further, the Hon'ble Division Bench in the order dated 4th May, 2020 held that the unanimous report of Joint ALPs has not been disputed. Further, the inventory of assets records the share holding held by the estate

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)

3 residence by ignoring the fact that such fees are subject to tax in India under section 9(1) read with section 195 of the act? (iv) Whether on the facts and in the circumstances of the case, the Learned Tribunal erred in law in deleting the disallowance of Rs.84,57,149/- under section 40(a)(i) on account

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

transferred to D-Mat account. Further it was stated that the equity shares of the company were sub-divided i.e for every one share having nominal value of Rs. 10, the equity holders got 10 shares of Rs. 1 and the assessee got 45,000 equity shares thus, totally holding 50,000 equity shares in the said company. The assessee