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30 results for “transfer pricing”+ Section 144C(10)clear

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Key Topics

Addition to Income16Section 143(3)10Section 153A8Section 10(3)8Section 144C8Section 2638Section 1487Section 56(2)(viib)6Section 68

DAMANDEEP KAUR,MOHALI vs. ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE-2), CHANDIGARH, CHANDIGARH

In the result, all appeals of the assessee are allowed

ITA 900/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh15 Dec 2025AY 2018-19

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

For Appellant: Shri Rohit Kapoor, Advocate &For Respondent: Shri Manav Bansal, CIT, DR
Section 10(3)Section 153ASection 245D(4)

Section 144C was intended for transfer-pricing matters; that BMA proceedings are independent and cannot bind AO; that participation cured the defect; and in any case the defect, if any, is cured u/s 292B. 15. We have heard the rival contention of the parties and perused the material available on the record. It is an admitted factual position that

DAMANDEEP KAUR,MOHALI vs. ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE-2), CHANDIGARH, CHANDIGARH

Showing 1–20 of 30 · Page 1 of 2

5
Transfer Pricing5
Deduction3
Penalty3

In the result, all appeals of the assessee are allowed

ITA 901/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh15 Dec 2025AY 2019-20
Section 10(3)Section 153ASection 245D(4)

144C was\nintended for transfer-pricing matters; that BMA proceedings are independent\nand cannot bind AO; that participation cured the defect; and in any case the\ndefect, if any, is cured u/s 292B.\n15.\nWe have heard the rival contention of the parties and perused the\nmaterial available on the record. It is an admitted factual position that the\nassessee

DAMANDEEP KAUR,MOHALI vs. ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE-2), CHANDIGARH, CHANDIGARH

In the result, all appeals of the assessee are allowed

ITA 902/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh15 Dec 2025AY 2020-21
Section 10(3)Section 153ASection 245D(4)

144C was\nintended for transfer-pricing matters; that BMA proceedings are independent\nand cannot bind AO; that participation cured the defect; and in any case the\ndefect, if any, is cured u/s 292B.\n15. We have heard the rival contention of the parties and perused the\nmaterial available on the record. It is an admitted factual position that the\nassessee

DAMANDEEP KAUR,MOHALI vs. ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE-2), CHANDIGARH, CHANDIGARH

In the result, all appeals of the assessee are allowed

ITA 899/CHANDI/2025[2016-17]Status: DisposedITAT Chandigarh15 Dec 2025AY 2016-17
For Appellant: Shri Rohit Kapoor, Advocate &For Respondent: Shri Manav Bansal, CIT, DR
Section 10(3)Section 153ASection 245D(4)

144C was\nintended for transfer-pricing matters; that BMA proceedings are independent\nand cannot bind AO; that participation cured the defect; and in any case the\ndefect, if any, is cured u/s 292B.\n\n15.\nWe have heard the rival contention of the parties and perused the\nmaterial available on the record. It is an admitted factual position that

SARASWATI AGRO CHEMICALS (INDIA) PVT. LTD,MOHALI vs. DCIT, CIRCLE-6(1), MOHALI

In the result, the transfer pricing adjustment so made by the AO and confirmed by the ld CIT(A) amounting to Rs 89,22,420/- is hereby set-aside and the ground of appeal is allowed

ITA 165/CHANDI/2024[2014-15]Status: DisposedITAT Chandigarh15 Oct 2024AY 2014-15

Bench: Or At The Time Of Hearing.”

For Appellant: Shri R.K. Gupta, C.A and Shri Akshun Gupta, C.AFor Respondent: Shri Vivek Vardhan, JCIT, Sr. DR
Section 143(1)Section 143(2)Section 143(3)Section 92BSection 92C

144C(1) of the Act. 4. Being aggrieved, the Assessee carried the matter in appeal before the Ld. CIT(A) who has sustained the said Transfer Pricing adjustment and the relevant findings of the ld CIT(A) read as under: “6.2 In this grounds of appeal the appellant has contested the addition of Rs. 89,22,440/- on account

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

144C(5) of Income Tax Act dated 25/07/2019, the concerned Transfer Pricing officer-1(3)(2), New Delhi passed an order dated 19.09.2019 giving effect to directions of Hon'ble DRP by revising the TP adjustment to Rs. 24,22,69,093/- against the earlier adjustment of Rs. 82,35,82,954/-. The relevant portion of the TP adjustment made

CENTRIENT PHARMACEUTICALS INDIA PRIVATE LIMITED,PUNJAB vs. DCIT/ ACIT, CIRCLE 1(1), CHANDIGARH, CHANDIGARH

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 1201/CHANDI/2024[AY 2021-22]Status: DisposedITAT Chandigarh26 Mar 2025

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ I.T.A. No. 1201/Chd/2024 "नधा"रण वष" / Assessment Year: 2021-22

For Appellant: Sh. Darpan Kirpalani, AdvocateFor Respondent: Sh. Rohit Shrma, CIT, D.R. (Virtual)
Section 143(3)Section 144Section 144CSection 144C(10)Section 153(1)Section 253(1)(d)

Transfer Pricing Grounds: Legal grounds Ground 1: That on the facts and circumstances of the case and in law, the impugned order passes by the Ld. AO is barred by limitation in terms of section 153(1)/(4) and therefore, is liable to be quashed. Ground 2: Based on the facts and circumstances of the present case

PAREXEL INTERNATIONAL SERVICES INDIA PVT.LTD,,CHANDIGARH vs. ACIT,CIRCLE-5(1),(NEAC), CHANDIGARH

In the result, the appeal of the Assessee is partly allowed

ITA 129/CHANDI/2021[2016-17]Status: DisposedITAT Chandigarh28 Oct 2024AY 2016-17

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Dhanesh Bafna, CAFor Respondent: Shri Reuben Mathew Jacob, Addl. CIT, Sr. DR
Section 143(3)Section 234BSection 271(1)(C)

144C(13) read with sections 143(3A) and 143(3B) of the Income Tax Act. Aggrieved therewith, the assessee is in appeal before us. 6. The facts relating to the order under appeal are that the assessee Parexel International Services India Private Limited (‘Parexel India’) is a wholly owned subsidiary of Parexel International (IRL) Ltd.(‘Parexel Ireland’). Parexel Ireland

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

144C(5) of the Act. 2. At the outset itself it was stated that the impugned appeals had earlier been listed for hearing alongwith the appeals for assessment year 2005-06 and assessment year 2006-07, in ITA No.2453/Del/2016 and ITA No.532/Chd/2014 ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys

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

144C(5) of the Act. 2. At the outset itself it was stated that the impugned appeals had earlier been listed for hearing alongwith the appeals for assessment year 2005-06 and assessment year 2006-07, in ITA No.2453/Del/2016 and ITA No.532/Chd/2014 ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys

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

144C(5) of the Act. 2. At the outset itself it was stated that the impugned appeals had earlier been listed for hearing alongwith the appeals for assessment year 2005-06 and assessment year 2006-07, in ITA No.2453/Del/2016 and ITA No.532/Chd/2014 ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys

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

144C(5) of the Act. 2. At the outset itself it was stated that the impugned appeals had earlier been listed for hearing alongwith the appeals for assessment year 2005-06 and assessment year 2006-07, in ITA No.2453/Del/2016 and ITA No.532/Chd/2014 ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys

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

144C(5) of the Act. 2. At the outset itself it was stated that the impugned appeals had earlier been listed for hearing alongwith the appeals for assessment year 2005-06 and assessment year 2006-07, in ITA No.2453/Del/2016 and ITA No.532/Chd/2014 ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys

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

144C(5) of the Act. 2. At the outset itself it was stated that the impugned appeals had earlier been listed for hearing alongwith the appeals for assessment year 2005-06 and assessment year 2006-07, in ITA No.2453/Del/2016 and ITA No.532/Chd/2014 ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys

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

144C(5) of the Act. 2. At the outset itself it was stated that the impugned appeals had earlier been listed for hearing alongwith the appeals for assessment year 2005-06 and assessment year 2006-07, in ITA No.2453/Del/2016 and ITA No.532/Chd/2014 ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys

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

144C(5) of the Act. 2. At the outset itself it was stated that the impugned appeals had earlier been listed for hearing alongwith the appeals for assessment year 2005-06 and assessment year 2006-07, in ITA No.2453/Del/2016 and ITA No.532/Chd/2014 ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys

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

144C(5) of the Act. 2. At the outset itself it was stated that the impugned appeals had earlier been listed for hearing alongwith the appeals for assessment year 2005-06 and assessment year 2006-07, in ITA No.2453/Del/2016 and ITA No.532/Chd/2014 ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys

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

144C(5) of the Act. 2. At the outset itself it was stated that the impugned appeals had earlier been listed for hearing alongwith the appeals for assessment year 2005-06 and assessment year 2006-07, in ITA No.2453/Del/2016 and ITA No.532/Chd/2014 ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys

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

144C(5) of the Act. 2. At the outset itself it was stated that the impugned appeals had earlier been listed for hearing alongwith the appeals for assessment year 2005-06 and assessment year 2006-07, in ITA No.2453/Del/2016 and ITA No.532/Chd/2014 ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys

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

144C(5) of the Act. 2. At the outset itself it was stated that the impugned appeals had earlier been listed for hearing alongwith the appeals for assessment year 2005-06 and assessment year 2006-07, in ITA No.2453/Del/2016 and ITA No.532/Chd/2014 ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys