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47 results for “transfer pricing”+ Section 109clear

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Key Topics

Section 26352Section 143(3)39Section 69A24Section 13(3)24Section 143(2)22Section 14815Addition to Income14Penalty11Section 148B

A.B. SUGARS LIMITED,PUNJAB vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, CHANDIGARH, CHANDIGARH

In the result, the appeal of the assessee is allowed

ITA 299/CHANDI/2024[2018-2019]Status: DisposedITAT Chandigarh16 Dec 2024AY 2018-2019

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri T.N. Singla, C.AFor Respondent: Shri Rohit Sharma, CIT DR
Section 143(3)Section 263Section 80ISection 92C

Section 263 does not visualize a case of substitution of the judgment of the Commissioner for that of the Transfer Pricing Officer, who passed the order, unless the decision is held to be erroneous. The words "prejudicial to the interests of the revenue" have not been defined, but they must mean that the orders challenged is such

Showing 1–20 of 47 · Page 1 of 3

10
Section 12710
Exemption9
Transfer Pricing3

A.B. SUGARS LIMITED,PUNJAB vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, CHANDIGARH

In the result, the appeal of the assessee is allowed

ITA 300/CHANDI/2024[2017-2018]Status: DisposedITAT Chandigarh16 Dec 2024AY 2017-2018

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri T.N. Singla, C.AFor Respondent: Shri Rohit Sharma, CIT DR
Section 143(3)Section 263Section 80ISection 92C

Section 263 does not visualize a case of substitution of the judgment of the Commissioner for that of the Transfer Pricing Officer, who passed the order, unless the decision is held to be erroneous. The words "prejudicial to the interests of the revenue" have not been defined, but they must mean that the orders challenged is such

M/S NECTAR LIFESCIENCE LTD.,CHANDIGARH vs. DCIT, C-1(1), CHANDIGARH

In the result, appeal of the assessee is allowed

ITA 1497/CHANDI/2019[2015-16]Status: DisposedITAT Chandigarh17 Feb 2022AY 2015-16
For Appellant: Shri Yogesh Monga, CAFor Respondent: Shri Sarabjeet Singh, CIT, DR
Section 144C(13)Section 144C(5)Section 271Section 80

transferred to Electricity Units Consumption Manufacturing Processes Apr-14 3,900,800 932,400 2,968,400 6.72 19,947,648 May-14 3,901,000 981,900 2,919,100 6.72 19,616,352 Jun-14 4,215,000 1,033,100 3,181,900 6.72 21,382,368 Jul-14 5,200,500 1,091,500 4,109

GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. DCIT, CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

ITA 227/CHANDI/2017[2010-11]Status: DisposedITAT Chandigarh26 Oct 2021AY 2010-11

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

M/S GLAXO SMITHKLINE ASIA PVT. LTD.,GURGAON vs. ACIT, C-4(1), CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

ITA 47/CHANDI/2018[2013-14]Status: DisposedITAT Chandigarh26 Oct 2021AY 2013-14

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

ACIT, CHANDIGARH vs. M/S GLAXO SMITHKLINE ASIA PVT. LTD., GURGAON

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

ITA 222/CHANDI/2017[2009-10]Status: DisposedITAT Chandigarh26 Oct 2021AY 2009-10

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. ACIT, CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

ITA 226/CHANDI/2017[2009-10]Status: DisposedITAT Chandigarh26 Oct 2021AY 2009-10

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

ACIT, CHANDIGARH vs. M/S GLAXO SMITHKLINE ASIA PVT. LTD., GURGAON

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

ITA 221/CHANDI/2017[2009-10]Status: DisposedITAT Chandigarh26 Oct 2021AY 2009-10

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. ACIT, CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

ITA 225/CHANDI/2017[2008-09]Status: DisposedITAT Chandigarh26 Oct 2021AY 2008-09

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

ACIT, CHANDIGARH vs. M/S GLAXO SMITHKLINE ASIA PVT. LTD., GURGAON

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

ITA 220/CHANDI/2017[2008-09]Status: DisposedITAT Chandigarh26 Oct 2021AY 2008-09

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

M/S GLAXO SMITHKLINE ASIA PVT. LTD.,GURGAON vs. ACIT, C-4(1), CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

ITA 1500/CHANDI/2018[2014-15]Status: DisposedITAT Chandigarh26 Oct 2021AY 2014-15

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

ACIT, CHANDIGARH vs. M/S GLAXO SMITHKLINE ASIA PVT. LTD., GURGAON

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

ITA 219/CHANDI/2017[2007-08]Status: DisposedITAT Chandigarh26 Oct 2021AY 2007-08

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

M/S GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. ACIT, CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

ITA 242/CHANDI/2017[2007-08]Status: DisposedITAT Chandigarh26 Oct 2021AY 2007-08

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. DCIT, CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

ITA 228/CHANDI/2017[2011-12]Status: DisposedITAT Chandigarh26 Oct 2021AY 2011-12

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

M/S GLAXO SMITHKLINE ASIA PVT. LTD.,NABHA vs. DCIT, C-4(1), CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

ITA 1495/CHANDI/2019[2015-16]Status: DisposedITAT Chandigarh26 Oct 2021AY 2015-16

price of international transaction of export of goods. Re: Incorrect exclusion of comparable by the TPO In this regard, it is respectfully submitted that while applying TNMM, the following companies excluded by the TPO in the impugned order ought to be considered as comparable for the reasons tabulated as under: Company Reasons for Remarks of the applicant Name Remarks

DY.CIT, CIRCLE-1(1), CHANDIGARH vs. M/S GLAXOSMITHKLINE CONSUMER PVT. LTD., NABHA

In the result, Revenue’s appeal is dismissed

ITA 121/CHANDI/2023[2016-17]Status: DisposedITAT Chandigarh16 Oct 2025AY 2016-17

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 121/Chd/2023 "नधा"रण वष" / Assessment Year : 2016-17 Dcit, M/S Glaxosmithkline Circle 1(1), बनाम Consumer Pvt. Ltd., Chandigarh Patiala Road, Vs. Nabha. Punjab "थायी लेखा सं./Pan No. Aafcg8415R अपीलाथ"/Appellant ""यथ"/Respondent ( Hybrid Mode ) "नधा"रती क" ओर से/Assessee By : Sh. Ajay Vohra, Sr. Advocate With Sh. Neeraj Jain, Advocate & Ms. Somya Jain, Ca (Virtual) राज"व क" ओर से/ Revenue By : Shri Manav Bansal, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 06.08.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 16.10.2025 आदेश/Order Per Krinwant Sahay, Am:

For Appellant: Sh. Ajay Vohra, Sr. Advocate with Sh. Neeraj Jain, Advocate and Ms. Somya Jain, For Respondent: Shri Manav Bansal, CIT DR
Section 32(1)

109 taxmann.com 47 (Del Trib.) - I&B Seeds Pvt Ltd vs. DCIT: 142 taxmann.com 274 (Bang Trib.) 18. In view of the aforesaid, since the predecessor, viz. Novartis in the present case, has not claimed depreciation on both tangible and intangible assets forming part of the OTC business transferred to the assessee by way of slump sale, the provisions

SURJEET SINGH,SIRSA vs. PCIT, ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 488/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

section 2 of section 56, clause(iv) in section 57 and clause (b) in Section 145A w.e.f. 01.04.2010. From the assessment year 2010-11 onwards, the amount of compensation or enhanced compensation is taxable as "income from other sources" after allowing deduction of a sum equal to 50% of such income in the year of receipt The Hon'ble Apex

SH. PARAMJEET SINGH,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 290/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

section 2 of section 56, clause(iv) in section 57 and clause (b) in Section 145A w.e.f. 01.04.2010. From the assessment year 2010-11 onwards, the amount of compensation or enhanced compensation is taxable as "income from other sources" after allowing deduction of a sum equal to 50% of such income in the year of receipt The Hon'ble Apex

SH. KASHMIR SINGH SANDHA,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 288/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

section 2 of section 56, clause(iv) in section 57 and clause (b) in Section 145A w.e.f. 01.04.2010. From the assessment year 2010-11 onwards, the amount of compensation or enhanced compensation is taxable as "income from other sources" after allowing deduction of a sum equal to 50% of such income in the year of receipt The Hon'ble Apex

SH. ARVAIL SINGH,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 286/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

section 2 of section 56, clause(iv) in section 57 and clause (b) in Section 145A w.e.f. 01.04.2010. From the assessment year 2010-11 onwards, the amount of compensation or enhanced compensation is taxable as "income from other sources" after allowing deduction of a sum equal to 50% of such income in the year of receipt The Hon'ble Apex