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227 results for “transfer pricing”+ Section 35clear

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Key Topics

Section 143(3)41Section 26339Addition to Income36Section 69A28Section 153A28Section 143(2)27Section 14821Section 13218Section 127

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

35,537/-. Subsequently, the case of the assessee was selected for scrutiny and during the course of assessment proceedings, the AO referred the case to the Transfer Pricing Officer (TPO) for computation of Arms Length Price under section

Showing 1–20 of 227 · Page 1 of 12

...
16
Penalty11
Unexplained Investment6
Deduction6

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

35,537/-. Subsequently, the case of the assessee was selected for scrutiny and during the course of assessment proceedings, the AO referred the case to the Transfer Pricing Officer (TPO) for computation of Arms Length Price under section

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

transferring the same to the non- exempt unit. In such eventuality arm's length price of steam is taken at NIL, resulting in adjustment of Rs.75,35,33,280/-. [Adjustment Rs.75,35,33,280 /-] 5.4 Thereafter the A.O. passed the draft assessment order dt. 28/12/2018 and proposed the addition of Rs. 82,35

M/S YAMUNA POWER & INFRASTRUCTURE LTD.,JAGADHRI vs. DCIT, CIRCLE, YAMUNANAGAR

In the result, the appeal of the assessee is allowed

ITA 1229/CHANDI/2019[2014-15]Status: DisposedITAT Chandigarh19 Jul 2024AY 2014-15

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

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Dharam Vir, JCIT, Sr. DR
Section 143(3)Section 271ASection 80ISection 92C

Transfer Pricing documentation which contained the functional and economic analysis of the assessee and the comparables and no adverse inference was drawn in respect of International and Specified Domestic Transactions so undertaken by the assessee in terms of his order passed under section 92CA(3) dt. 28/09/2017. At the same time, the TPO in his order has stated that

SAHIBZADA TIMBER AND PLY PRIVATE LIMITED ,MOHALI vs. DCIT, ACIT CENTRAL CIRCLE-2, CHANDIGARH, CHANDIGARH

In the result, the appeal of the assessee is dismissed

ITA 699/CHANDI/2024[2019-20]Status: DisposedITAT Chandigarh19 Feb 2025AY 2019-20

Bench: SHRI. VIKRAM SINGH YADAV, AM आयकर अपील सं./ ITA No. 699/Chd/2024 निर्धारण वर्ष / Assessment Year : 2019-20 M/s Sahibzada Timber & Ply Private Limited B41-42, Phase-3, Indl. Aera, SAS Nagar Mohali, Punjab बनाम The DCIT Central Circle-2 Chandigarh स्थायी लेखा सं./PAN NO: AAQCS2239G अपीलार्थी/Appellant प्रत्यर्थी/Respondent निर्धारिती की ओर से/Assessee by : Shri Mohit Dhiman, C.A राजस्व की ओर से/ Revenue by : Dr. Ranjeet Kaur, Sr. DR Shri Dharam Vir, Addl. CIT, Sr.DR सुनवाई की तारीख/Date of He

For Appellant: Shri Mohit Dhiman, C.AFor Respondent: Dr. Ranjeet Kaur, Sr. DR
Section 250(6)Section 50C

transfer of the capital asset has not been presented for registration. The expression 'assessable' would permit the Revenue authorities to apply what is popularly referred to as Jantri rates with respect to the land in question for the purpose of section 48 of the Act with aid of deeming fiction contained in sub-section (1) of section

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)

35 Lakhs before 1-4-2001 and valuer has valued at Rs 1.66 crore & there is no reason to disbelief the valuation done by Income tax Registered valuer. 14. Ld. AR also submitted that the collector rate is always fixed as minimum rate in order to collect stamp duty and FMV cannot be compared with collector rate.Ld. AR submitted that

DEPUTY COMMISSIONER OF INCOME TAX, CHANDIGARH vs. JAMES HOTELS LTD, CHANDIGARH

ITA 552/CHANDI/2023[2012-13]Status: DisposedITAT Chandigarh01 Oct 2024AY 2012-13

Bench: The Said Resolution To Enhance Authorized Share Capital.

For Appellant: Shri R.K. KapoorFor Respondent: Shri Rohit Sharma, CIT, DR
Section 143(2)Section 269SSection 271D

Transfer Pricing Officer and thereafter the Ld. AO changed the nature of transaction from share application money and treated it as loan on which notional interest was computed and the Tribunal held that AO has no power to reclassify the transaction from the share application money to loan. 8.3 It was further submitted that while levying the penalty, Additional

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

ITA 796/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh25 Nov 2024AY 2018-19

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

Section 142(1)Section 143(2)Section 143(3)Section 246ASection 250(6)Section 253Section 263

price in consideration of immediate payment or payment within the stipulated period.” 17.3 This income has been shown as part of “profit and gain of business” and that the same has been accepted as such in past years too. There is no dispute that it is not a “business income” nor the same has been assessed as “income from other

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, , AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

ITA 817/CHANDI/2023[2014-15]Status: DisposedITAT Chandigarh25 Nov 2024AY 2014-15

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

Section 142(1)Section 143(2)Section 143(3)Section 246ASection 250(6)Section 253Section 263

price in consideration of immediate payment or payment within the stipulated period.” 17.3 This income has been shown as part of “profit and gain of business” and that the same has been accepted as such in past years too. There is no dispute that it is not a “business income” nor the same has been assessed as “income from other

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4,, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

ITA 794/CHANDI/2023[2016-17]Status: DisposedITAT Chandigarh25 Nov 2024AY 2016-17

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

Section 142(1)Section 143(2)Section 143(3)Section 246ASection 250(6)Section 253Section 263

price in consideration of immediate payment or payment within the stipulated period.” 17.3 This income has been shown as part of “profit and gain of business” and that the same has been accepted as such in past years too. There is no dispute that it is not a “business income” nor the same has been assessed as “income from other

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, LUDHIANA, - vs. ROCKMAN INDUSTRIES LTD, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

ITA 818/CHANDI/2023[2015-16]Status: DisposedITAT Chandigarh25 Nov 2024AY 2015-16

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

Section 142(1)Section 143(2)Section 143(3)Section 246ASection 250(6)Section 253Section 263

price in consideration of immediate payment or payment within the stipulated period.” 17.3 This income has been shown as part of “profit and gain of business” and that the same has been accepted as such in past years too. There is no dispute that it is not a “business income” nor the same has been assessed as “income from other

DY. COMMISSIONER OF INCOME TAX, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, FOCAL POINT

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

ITA 84/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh25 Nov 2024AY 2020-21

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

Section 142(1)Section 143(2)Section 143(3)Section 246ASection 250(6)Section 253Section 263

price in consideration of immediate payment or payment within the stipulated period.” 17.3 This income has been shown as part of “profit and gain of business” and that the same has been accepted as such in past years too. There is no dispute that it is not a “business income” nor the same has been assessed as “income from other

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

ITA 795/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh25 Nov 2024AY 2017-18

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

Section 142(1)Section 143(2)Section 143(3)Section 246ASection 250(6)Section 253Section 263

price in consideration of immediate payment or payment within the stipulated period.” 17.3 This income has been shown as part of “profit and gain of business” and that the same has been accepted as such in past years too. There is no dispute that it is not a “business income” nor the same has been assessed as “income from other

DCIT CIRCLE-4, LUDHIANA, LUDHIANA vs. ROCKMAN INDUSTRIES LTD, LUDHIANA

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

ITA 748/CHANDI/2023[2010-11]Status: DisposedITAT Chandigarh25 Nov 2024AY 2010-11

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

Section 142(1)Section 143(2)Section 143(3)Section 246ASection 250(6)Section 253Section 263

price in consideration of immediate payment or payment within the stipulated period.” 17.3 This income has been shown as part of “profit and gain of business” and that the same has been accepted as such in past years too. There is no dispute that it is not a “business income” nor the same has been assessed as “income from other

ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-4, AAYAKAR BHAWAN vs. ROCKMAN INDUSTRIES LIMITED, -

In the result order of CIT(A) is sustained as passed and the appeal of the Revenue is partly allowed for statistical purposes

ITA 177/CHANDI/2024[2013-14]Status: DisposedITAT Chandigarh25 Nov 2024AY 2013-14

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

Section 142(1)Section 143(2)Section 143(3)Section 246ASection 250(6)Section 253Section 263

price in consideration of immediate payment or payment within the stipulated period.” 17.3 This income has been shown as part of “profit and gain of business” and that the same has been accepted as such in past years too. There is no dispute that it is not a “business income” nor the same has been assessed as “income from other

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

35 of 120 to which are on record ,can be raised before the Tribunal for the first time. It was emphasized in the decision that the purpose of assessment proceedings is to correctly assess the tax liability of assessees in accordance with law and to this end the power of the Tribunal cannot be restricted only to decide issues which

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

35 of 120 to which are on record ,can be raised before the Tribunal for the first time. It was emphasized in the decision that the purpose of assessment proceedings is to correctly assess the tax liability of assessees in accordance with law and to this end the power of the Tribunal cannot be restricted only to decide issues which

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

35 of 120 to which are on record ,can be raised before the Tribunal for the first time. It was emphasized in the decision that the purpose of assessment proceedings is to correctly assess the tax liability of assessees in accordance with law and to this end the power of the Tribunal cannot be restricted only to decide issues which

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

35 of 120 to which are on record ,can be raised before the Tribunal for the first time. It was emphasized in the decision that the purpose of assessment proceedings is to correctly assess the tax liability of assessees in accordance with law and to this end the power of the Tribunal cannot be restricted only to decide issues which

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

35 of 120 to which are on record ,can be raised before the Tribunal for the first time. It was emphasized in the decision that the purpose of assessment proceedings is to correctly assess the tax liability of assessees in accordance with law and to this end the power of the Tribunal cannot be restricted only to decide issues which