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29 results for “transfer pricing”+ Section 144C(8)clear

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Key Topics

Addition to Income15Section 153A8Section 10(3)8Section 143(3)8Section 2638Section 1487Section 144C7Section 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)

Transfer Pricing Officer made a variation to the Arm's Length Price and valued the transaction at Rs. 517.82 per share. In other words, he recommended a variation in the Arm's Length Price. In these circumstances, the Petitioner would certainly be an eligible Assessee as contemplated under Section 144C(15)(b) (i) of the IT Act. Since this variation

Showing 1–20 of 29 · Page 1 of 2

5
Transfer Pricing4
Deduction3
Penalty3

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)

8 | | |\n| 2022-23 | 01.04.2022\n14-07-2022 | 104 | 104 | 261 | Resident\n\nThus, the assessee's non-resident status under section 6 of the Act stands\nundisputed and accepted by all revenue authorities including the CIT(A) and\nthe BMA authority.\n12. The assessee in written submissions has contended that once she is\naccepted as a non-resident

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

8 | 204 | 161 | Non-Resident\n| | 01.04.2022 | 14-07-2022 | 104 | 104 | 261 | Resident\n\nThus, the assessee's non-resident status under section 6 of the Act stands\nundisputed and accepted by all revenue authorities including the CIT(A) and\nthe BMA authority.\n12.\nThe assessee in written submissions has contended that once she is\naccepted

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)

8 | | | |\n| 2022-23 | 01.04.2022 | 14-07-2022 | 104 | 104 | 261 | Resident |\n\nThus, the assessee's non-resident status under section 6 of the Act stands\nundisputed and accepted by all revenue authorities including the CIT(A) and\nthe BMA authority.\n\n12.\nThe assessee in written submissions has contended that once she is\naccepted as a non-resident

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

section (8) of s. 80IA and s. 92F of the Act. Under the facts and circumstances of the case, application of external CUP, as done by the TPO, was the only method which could be considered for determining the ALP of the power transferred to non-eligible units. The TPO has observed that the units which are not used

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

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)

Pricing adjustment order, which is under challenge before us. 3 5. Vide order dt. 31/03/2021, assessment was finalised by the National e- Assessment Centre, Delhi, pursuant to directions of the Dispute Resolution Panel, under section 143(3) r.w.s. 144C(13) read with sections 143(3A) and 143(3B) of the Income Tax Act. Aggrieved therewith, the assessee is in appeal

SH. RAJINDER SINGH BEDI,CHANDIGARH vs. DCIT (INTL. TAXATION), CHANDIGARH

In the result, appeal of the assessee is allowed

ITA 538/CHANDI/2022[2018-19]Status: DisposedITAT Chandigarh04 Jun 2025AY 2018-19

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 538/Chd/2022 "नधा"रण वष" / Assessment Year: 2018-19 Shri Rajinder Singh Bedi, The Dcit, (Int.Taxation ), 1368, Sector 40-B, Vs Chandigarh. Chandigarh. "थायी लेखा सं./Pan No: Afwpb3355A अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Sudhir Sehgal, Advocate Revenue By : Smt. Kusum Bansal, Cit, Dr Date Of Hearing : 09.04.2025 Date Of Pronouncement : 04.06.2025 Hybrid Hearing O R D E R

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Smt. Kusum Bansal, CIT, DR
Section 143(2)Section 143(3)Section 144Section 144CSection 144C(13)Section 144C(2)(b)Section 144C(5)

144C of the Income Tax Act The Assessing Officer is directed to complete the assessment as per the above directions of the Dispute Resolution Panel. The Assessing Officer shall place a copy of these directions as annexure to the final order, to be read as a part of the order. While passing the final order, the Assessing Officer shall incorporate

AUTHORGEN TECHNOLOGIES PVT. LTD.,MOHALI vs. ITO, WARD 6(1), CHANDIGARH

ITA 212/CHANDI/2023[2015-16]Status: DisposedITAT Chandigarh02 Sept 2024AY 2015-16

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri K.M. Gupta, AdvocateFor Respondent: Shri J.S. Kahlon, CIT, DR &
Section 143(3)Section 263Section 56(2)(viib)Section 68

transfer pricing amounting to Rs. 8,21,51,007/-, addition on account of ESI/EPF amounting to Rs. 18,81,760/- and disallowance under section 14A amounting to Rs. 8,35,083/-. 7.1 The assessee company thereafter carried the matter in appeal before the Ld. CIT(A) by filing an appeal on 23/01/2019. In the meantime, before the appeal could

M/S AUTHORGEN TECHNOLOGIES PVT.LTD,MOHALI vs. PR.CIT-1, CHANDIGARH

ITA 171/CHANDI/2021[2015-16]Status: DisposedITAT Chandigarh02 Sept 2024AY 2015-16

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri K.M. Gupta, AdvocateFor Respondent: Shri J.S. Kahlon, CIT, DR &
Section 143(3)Section 263Section 56(2)(viib)Section 68

transfer pricing amounting to Rs. 8,21,51,007/-, addition on account of ESI/EPF amounting to Rs. 18,81,760/- and disallowance under section 14A amounting to Rs. 8,35,083/-. 7.1 The assessee company thereafter carried the matter in appeal before the Ld. CIT(A) by filing an appeal on 23/01/2019. In the meantime, before the appeal could

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

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. 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

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 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

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

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 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