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54 results for “transfer pricing”+ Section 253(4)clear

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Key Topics

Section 143(2)41Section 143(3)35Section 26334Addition to Income24Section 69A22Section 25321Section 14818Section 250(6)16Section 142(1)

DCIT, C-1(1) , CHANDIGARH vs. M/S FIDELITY INFORMATION SERVICES INDIA PVT. LTD., CHANDIGARH

In the result, the cross-objection filed by the assessee is dismissed

ITA 1328/CHANDI/2019[2014-15]Status: DisposedITAT Chandigarh07 Jun 2024AY 2014-15

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

For Appellant: Shri Vishal Kalra, Advocate and Ms. Sumisha, C.AFor Respondent: Shri Rohit Sharma, CIT DR
Section 37(1)

transfer pricing study report prepared for those assessment years and the orders passed in Assessee company’s case in the earlier years. In a nutshell, the Hon'ble Tribunal while passing the order for assessment years 2011-12 and 2012-13 had considered all the relevant documents and after considering the arguments of Revenue and Assessee company had decided

DESH MITTER GAIND,PANCHKULA vs. INCOME TAX OFFICER, WARD-1, PANCHKULA, PANCHKULA, HARYANA

ITA 454/CHANDI/2023[2011-12]Status: Disposed

Showing 1–20 of 54 · Page 1 of 3

14
Penalty10
Limitation/Time-bar7
Long Term Capital Gains5
ITAT Chandigarh
29 Jan 2025
AY 2011-12

Bench: This Tribunal. The Assessee Is Aggrieved By The Order Of Cit(A) Bearing No. Itba/Nfac/S/250/2023-

For Appellant: Shri Yogesh Monga, CAFor Respondent: Shri Vivek Vardhan, JCIT-Sr.DR
Section 143(2)Section 148Section 250Section 253Section 48Section 50C

253 of the Income Tax Act, 1961 (hereinafter referred to as Act) as and by way of second appeal before this Tribunal. The assessee is aggrieved by the order OF CIT(A) bearing No. ITBA/NFAC/S/250/2023- 24/1053342436(1) dated 31.05.2023 which is ITA 454/CHD/2023 A.Y. 2011-12 2 hereinafter referred to as the “Impugned Order” which is passed under Section

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)

253(1)(d) of the Income-tax Act, 1961 (Act), against assessment order dated 25 October 2024 ("impugned order") passed by the Assessment Unit, Income Tax Department (Ld. 'AO") under section 143(3) read with section 144C read with section 1448 of the Act in pursuance of directions dated 26 September 2024 issued by Ld. Dispute Resolution Panel

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

253 of the Act grants right of appeal to the assessee, aggrieved by any of the orders specified therein , to the ITAT. As per Section 254 of the Act, the ITAT may after giving both the parties to the appeal an opportunity of being heard, pass such orders thereon as it deems fit. Rule 11 of the ITAT Rules

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

253 of the Act grants right of appeal to the assessee, aggrieved by any of the orders specified therein , to the ITAT. As per Section 254 of the Act, the ITAT may after giving both the parties to the appeal an opportunity of being heard, pass such orders thereon as it deems fit. Rule 11 of the ITAT Rules

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

253 of the Act grants right of appeal to the assessee, aggrieved by any of the orders specified therein , to the ITAT. As per Section 254 of the Act, the ITAT may after giving both the parties to the appeal an opportunity of being heard, pass such orders thereon as it deems fit. Rule 11 of the ITAT Rules

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

253 of the Act grants right of appeal to the assessee, aggrieved by any of the orders specified therein , to the ITAT. As per Section 254 of the Act, the ITAT may after giving both the parties to the appeal an opportunity of being heard, pass such orders thereon as it deems fit. Rule 11 of the ITAT Rules

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

253 of the Act grants right of appeal to the assessee, aggrieved by any of the orders specified therein , to the ITAT. As per Section 254 of the Act, the ITAT may after giving both the parties to the appeal an opportunity of being heard, pass such orders thereon as it deems fit. Rule 11 of the ITAT Rules

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

253 of the Act grants right of appeal to the assessee, aggrieved by any of the orders specified therein , to the ITAT. As per Section 254 of the Act, the ITAT may after giving both the parties to the appeal an opportunity of being heard, pass such orders thereon as it deems fit. Rule 11 of the ITAT Rules

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

253 of the Act grants right of appeal to the assessee, aggrieved by any of the orders specified therein , to the ITAT. As per Section 254 of the Act, the ITAT may after giving both the parties to the appeal an opportunity of being heard, pass such orders thereon as it deems fit. Rule 11 of the ITAT Rules

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

253 of the Act grants right of appeal to the assessee, aggrieved by any of the orders specified therein , to the ITAT. As per Section 254 of the Act, the ITAT may after giving both the parties to the appeal an opportunity of being heard, pass such orders thereon as it deems fit. Rule 11 of the ITAT Rules

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

253 of the Act grants right of appeal to the assessee, aggrieved by any of the orders specified therein , to the ITAT. As per Section 254 of the Act, the ITAT may after giving both the parties to the appeal an opportunity of being heard, pass such orders thereon as it deems fit. Rule 11 of the ITAT Rules

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

253 of the Act grants right of appeal to the assessee, aggrieved by any of the orders specified therein , to the ITAT. As per Section 254 of the Act, the ITAT may after giving both the parties to the appeal an opportunity of being heard, pass such orders thereon as it deems fit. Rule 11 of the ITAT Rules

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

253 of the Act grants right of appeal to the assessee, aggrieved by any of the orders specified therein , to the ITAT. As per Section 254 of the Act, the ITAT may after giving both the parties to the appeal an opportunity of being heard, pass such orders thereon as it deems fit. Rule 11 of the ITAT Rules

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

253 of the Act grants right of appeal to the assessee, aggrieved by any of the orders specified therein , to the ITAT. As per Section 254 of the Act, the ITAT may after giving both the parties to the appeal an opportunity of being heard, pass such orders thereon as it deems fit. Rule 11 of the ITAT Rules

M/S DSM SINOCHEM PHARMACEUTICALS INDIA PVT. LTD. ,TOANSA vs. DCIT, C-1(1), CHANDIGARH

In the result, appeal of the assessee is partly allowed

ITA 1592/CHANDI/2018[2014-15]Status: DisposedITAT Chandigarh20 Jan 2022AY 2014-15

Bench: Shri N.K. Saini, Vice- & Shri Vikas Awasthyआअसं. 253/ चंडीगढ़/2016(िन.व. 2011-12)

For Appellant: Sh.K.M Gupta, Adv., Sh. NishantFor Respondent: Sh. Vikram Batra, CIT-DR
Section 144

Transfer Pricing Adjustment of Rs.8,05,24,450/- in respect of corporate services fees. The TPO applied CUP as the most appropriate method and determined ALP of the transaction as Nil. The TPO has further observed that no independent party would have made a similar 4 आअसं.253/ चंडीगढ़/2016(िन.व.2011-12) आअसं.1592/ चंडीगढ़/2018

DSM SINOCHEM PHARMACEUTICALS INDIA PRIVATE LIMITED,NAWANSHAHR vs. DCIT, CHANDIGARH

In the result, appeal of the assessee is partly allowed

ITA 253/CHANDI/2016[2011-12]Status: DisposedITAT Chandigarh20 Jan 2022AY 2011-12

Bench: Shri N.K. Saini, Vice- & Shri Vikas Awasthyआअसं. 253/ चंडीगढ़/2016(िन.व. 2011-12)

For Appellant: Sh.K.M Gupta, Adv., Sh. NishantFor Respondent: Sh. Vikram Batra, CIT-DR
Section 144

Transfer Pricing Adjustment of Rs.8,05,24,450/- in respect of corporate services fees. The TPO applied CUP as the most appropriate method and determined ALP of the transaction as Nil. The TPO has further observed that no independent party would have made a similar 4 आअसं.253/ चंडीगढ़/2016(िन.व.2011-12) आअसं.1592/ चंडीगढ़/2018

SHRI SATISH SOIN,LUDHIANA vs. ACIT, CC-II, LUDHIANA

In the result, appeal of the assessee is allowed

ITA 303/CHANDI/2019[2012-13]Status: DisposedITAT Chandigarh23 Jul 2025AY 2012-13

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 303/Chd/2019 "नधा"रण वष" / Assessment Year : 2012-13 Shri Satish Soin, बनाम The Acit, House No.31, Garden Enclave, Central Circle-2, Vs South City-Ii, Ludhiana. Ludhiana. "थायी लेखा सं./Pan /Tan No: Advps6254N अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri Ashwani Kumar & Ms. Muskan Garg, Cas राज"व क" ओर से/ Revenue By : Smt. Kusum Bansal, Cit Dr तार"ख/Date Of Hearing : 26.05.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 23.07.2025 Hybrid Hearing आदेश/Order Per Rajpal Yadav, Vp

For Appellant: Shri Ashwani Kumar &For Respondent: Smt. Kusum Bansal, CIT DR
Section 10(38)Section 132Section 143(3)Section 153ASection 153DSection 263

253 contemplates that the Tribunal may admit an appeal or permit filing of memorandum of cross- objections after expiry of relevant period, if it is satisfied that there was a sufficient cause for not presenting it within that period. This expression sufficient cause employed in the section has also been used identically in sub-section 3 of section

M/S ASHA TECHNOLOGIES,SIRMOUR vs. ADDL. CIT, SOLAN

In the result, both the above appeals of the Assessee are partly allowed as aforesaid in respect of impugned orders dt

ITA 388/CHANDI/2012[2007-08]Status: DisposedITAT Chandigarh19 Jul 2024AY 2007-08

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

For Appellant: Shri Vishal Mohan, Sr. Advocate with Shri Aditya Sood, AdvocateFor Respondent: Shri Sarabjeet Singh, CIT, DR
Section 142(1)Section 143(2)Section 250Section 253Section 80I

253 of the Income Tax Act, 1961. The order of Ld. CIT(A) dt. 30/01/2012 in the aforesaid appeal No. IT/315/2009-10/Sml is hereinafter referred to as “impugned order”. Factual Matrix 1. The assessee M/s Asha Technologies is a partnership firm. The relevant AY is 2007-08. The corresponding previous year is 2006-07. The assessee firm is engaged

M/S ASHA TECHNOLOGIES,KALA AMB vs. ITO, SIRMOUR

In the result, both the above appeals of the Assessee are partly allowed as aforesaid in respect of impugned orders dt

ITA 61/CHANDI/2013[2009-10]Status: DisposedITAT Chandigarh19 Jul 2024AY 2009-10

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

For Appellant: Shri Vishal Mohan, Sr. Advocate with Shri Aditya Sood, AdvocateFor Respondent: Shri Sarabjeet Singh, CIT, DR
Section 142(1)Section 143(2)Section 250Section 253Section 80I

253 of the Income Tax Act, 1961. The order of Ld. CIT(A) dt. 30/01/2012 in the aforesaid appeal No. IT/315/2009-10/Sml is hereinafter referred to as “impugned order”. Factual Matrix 1. The assessee M/s Asha Technologies is a partnership firm. The relevant AY is 2007-08. The corresponding previous year is 2006-07. The assessee firm is engaged