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73 results for “transfer pricing”+ Section 6(2)clear

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Key Topics

Section 260A19Section 15411Section 409Section 144C9Section 143(3)8Addition to Income8Transfer Pricing6Section 1955Section 94

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

6) of Section 80A, that the express “market value” in relation to any goods or services sold, supplied or acquired means the “arm’s length price” as defined in clause (ii) of section 92F of such goods or services, if it is a specified domestic transaction referred to in section 92BA? (d) Whether on the facts and in the circumstances

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

Showing 1–20 of 73 · Page 1 of 4

Section 143(1)4
Comparables/TP4
Disallowance3

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

6) of Section 80A, that the express “market value” in relation to any goods or services sold, supplied or acquired means the “arm’s length price” as defined in clause (ii) of section 92F of such goods or services, if it is a specified domestic transaction referred to in section 92BA? (d) Whether on the facts and in the circumstances

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

6) of Section 80A, that the express “market value” in relation to any goods or services sold, supplied or acquired means the “arm’s length price” as defined in clause (ii) of section 92F of such goods or services, if it is a specified domestic transaction referred to in section 92BA? (d) Whether on the facts and in the circumstances

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

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 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-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 (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-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

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

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

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

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