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168 results for “transfer pricing”+ Section 17(1)clear

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Key Topics

Section 26370Addition to Income42Section 143(3)39Section 153A28Section 80I25Section 143(2)23Section 14822Section 69A21Section 147

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

Transfer Pricing- 1(3)(1), Delhi examined the documentation prescribed under Rule 10D and other details were called for and examined and passed order under section 92CA(3) dt. 31/07/2021 holding that in view of the functional and economic analysis of the assessee and comparables which have been examined, no adverse inference is drawn in respect of the Specified Domestic

Showing 1–20 of 168 · Page 1 of 9

...
17
Deduction11
Long Term Capital Gains9
Disallowance8

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

Transfer Pricing- 1(3)(1), Delhi examined the documentation prescribed under Rule 10D and other details were called for and examined and passed order under section 92CA(3) dt. 31/07/2021 holding that in view of the functional and economic analysis of the assessee and comparables which have been examined, no adverse inference is drawn in respect of the Specified Domestic

SANJEEV KUMAR KATHURIA,YAMUNA NAGAR vs. INCOME TAX OFFICER WARD 1 , YAMUNANAGAR

In the result, the appeal of the assessee is allowed

ITA 329/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh27 Feb 2025AY 2018-19

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

For Appellant: Shri Ajay Jain, C.AFor Respondent: Smt. Kusum Bansal, CIT, DR
Section 143(2)Section 143(3)Section 263Section 40A(3)

price with low level of construction which cannot be compared with residential house on independent plot in posh area. 15. The Ld. AR further submitted that PCIT has placed reliance on gift deed dated 8/10/2009 executed in favour of the assessee by his father. Stamp duty is charged on minimum collector for stamp duty purposes and it cannot reflect

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)

Transfer Pricing Officer made a variation to the Arm's Length\nPrice and valued the transaction at Rs.517.82 per share. In other words, he\nrecommended a variation in the Arm's Length Price. In these circumstances, the\nPetitioner would certainly be an eligible Assessee as contemplated under Section\n144C(15)(b) (i) of the IT Act. Since this variation

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)

Transfer Pricing Officer made a variation to the Arm's Length\nPrice and valued the transaction at Rs.517.82 per share. In other words, he\nrecommended a variation in the Arm's Length Price. In these circumstances, the\nPetitioner would certainly be an eligible Assessee as contemplated under Section\n144C(15)(b) (i) of the IT Act. Since this variation

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)

Transfer Pricing Officer made a variation to the Arm's Length\nPrice and valued the transaction at Rs.517.82 per share. In other words, he\nrecommended a variation in the Arm's Length Price. In these circumstances, the\nPetitioner would certainly be an eligible Assessee as contemplated under Section\n144C(15)(b) (i) of the IT Act. Since this variation

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)

17. In the opinion of this court, section 144C is a self contained provision which carves out a separate class of assesses, i. e., "eligible assessee", i. e., any person in whose case the variation arises as a consequence of the order of the Transfer Pricing Officer passed under sub-section (3) of section 92CA. For this class of assessees

SH. VIBHAV JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

ITA 355/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh16 Feb 2024AY 2013-14

Bench: SHRI. SANJAY GARG (Judicial Member), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Smt. Kusum Bansal, CIT DR
Section 10(36)Section 10(38)Section 143(1)Section 143(2)Section 153A

price have already been mentioned therein and the assessment was duly framed under section 143(1) of the Act and thus it was a case of an unabated assessment. 6.1 It was submitted that the said disclosed income / documents cannot be treated as incriminating material. It was further submitted that there is no evidence or document which was found

SH. ASHISH JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

ITA 353/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh23 Jan 2024AY 2013-14

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

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Rohit Sharma, CIT DR
Section 10(38)Section 153A

price have already been mentioned therein and the assessment was duly framed under section 143(1) of the Act and thus it was a case of an unabated assessment. 7.1 It was submitted that the said disclosed income / documents cannot be treated as incriminating material. It was further submitted that there is no evidence or document which was found

SH. AKHIL JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

ITA 351/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh23 Jan 2024AY 2013-14

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

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Rohit Sharma, CIT DR
Section 10(38)Section 153A

price have already been mentioned therein and the assessment was duly framed under section 143(1) of the Act and thus it was a case of an unabated assessment. 7.1 It was submitted that the said disclosed income / documents cannot be treated as incriminating material. It was further submitted that there is no evidence or document which was found

SH. ASHISH JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

ITA 352/CHANDI/2023[2012-13]Status: DisposedITAT Chandigarh23 Jan 2024AY 2012-13

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

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Rohit Sharma, CIT DR
Section 10(38)Section 153A

price have already been mentioned therein and the assessment was duly framed under section 143(1) of the Act and thus it was a case of an unabated assessment. 7.1 It was submitted that the said disclosed income / documents cannot be treated as incriminating material. It was further submitted that there is no evidence or document which was found

SH. BIPAN JAIN,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, the ground no

ITA 354/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh23 Jan 2024AY 2013-14

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

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Rohit Sharma, CIT DR
Section 10(38)Section 153A

price have already been mentioned therein and the assessment was duly framed under section 143(1) of the Act and thus it was a case of an unabated assessment. 7.1 It was submitted that the said disclosed income / documents cannot be treated as incriminating material. It was further submitted that there is no evidence or document which was found

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

Transfer Pricing Officer the aggregate value of specified domestic transactions has been taken from the Form 3CEB filed by the appellant. Perusal of Form 3CEB, prescribed under Rule 10E, states as "Report from an accountant to be furnished under section 92E relating to International Transaction(s) and Specified domestic transaction(s). The particulars of the above transaction(s) required

KAKA SINGH ALIAS GULJAR SINGH,PATIALA vs. INCOME TAX OFFICER , PATIALA

ITA 663/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh11 Nov 2025AY 2020-21
For Respondent: \nShri Suraj Bhan Nain, Advocate

transfer\nof agricultural land, it no where provides as to what is to be included under the head\n\"Capital gains\". The argument raised is not well founded.\n11. Learned counsel has relied on Circular No. 5 of 2010 by merely reading clause\n46. 1. The said clause talks about undue hardship being caused as arrears of interest\nbeing taxable

ARJESH KUMAR,PATIALA vs. ITO NATIONAL E-ASSESSMENT CENTRE , DELHI

ITA 876/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19
For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

Section 16 or Section 17 of the Act. We, therefore, hold that the statutory interest paid under Section 34 of the Act is interest paid for the delayed payment of the compensation amount and, therefore, is a revenue receipt liable to tax under the Income Tax Act." 9. This position of law has been consistently reiterated by this Court

RANJIT SINGH,PANCHKULA vs. DEPUTY DIRECTOR, CPC DEPARTMENT

ITA 992/CHANDI/2025[2023-24]Status: DisposedITAT Chandigarh11 Nov 2025AY 2023-24

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

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

Section 16 or Section 17 of the Act. We, therefore, hold that the statutory interest paid under Section 34 of the Act is interest paid for the delayed payment of the compensation amount and, therefore, is a revenue receipt liable to tax under the Income Tax Act." 9. This position of law has been consistently reiterated by this Court

PAWAN KUMAR,FATEHABAD vs. INCOME TAX OFFICER WARD-1, FATEHABAD

ITA 1112/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19

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

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

Section 16 or Section 17 of the Act. We, therefore, hold that the statutory interest paid under Section 34 of the Act is interest paid for the delayed payment of the compensation amount and, therefore, is a revenue receipt liable to tax under the Income Tax Act." 9. This position of law has been consistently reiterated by this Court

INCOME TAX OFFICER, FATEHABAD vs. MAHESH NAGPAL, FATEHABAD

ITA 531/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19

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

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

Section 16 or Section 17 of the Act. We, therefore, hold that the statutory interest paid under Section 34 of the Act is interest paid for the delayed payment of the compensation amount and, therefore, is a revenue receipt liable to tax under the Income Tax Act." 9. This position of law has been consistently reiterated by this Court

SH. AMARDEEP SINGH ATHWAL,YAMUNANAGAR vs. ITO, WARD-1, YAMUNANAGAR

ITA 566/CHANDI/2023[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16

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

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

Section 16 or Section 17 of the Act. We, therefore, hold that the statutory interest paid under Section 34 of the Act is interest paid for the delayed payment of the compensation amount and, therefore, is a revenue receipt liable to tax under the Income Tax Act." 9. This position of law has been consistently reiterated by this Court

BALBIR KUMAR HUF,CHANDIGARH vs. ITO , CHANDIGARH

ITA 172/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh11 Nov 2025AY 2017-18

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

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

Section 16 or Section 17 of the Act. We, therefore, hold that the statutory interest paid under Section 34 of the Act is interest paid for the delayed payment of the compensation amount and, therefore, is a revenue receipt liable to tax under the Income Tax Act." 9. This position of law has been consistently reiterated by this Court