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125 results for “transfer pricing”+ Section 63clear

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Key Topics

Section 26356Section 153A40Section 13236Addition to Income31Section 80I26Section 143(3)24Section 13(3)24Deduction19Section 153D

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 Officer has already examined the records and accepted the returned income. The copy of the order passed by TPO is attached as per Annexure-D and Reply submitted before TPO and A.O. along with annexures is enclosed as per Annexure-E for your honors kind perusal. "In the annexed reply submitted to TPO dated 17.11.2020- Annexure

Showing 1–20 of 125 · Page 1 of 7

18
Deemed Dividend17
Section 250(6)16
Depreciation12

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 Officer has already examined the records and accepted the returned income. The copy of the order passed by TPO is attached as per Annexure-D and Reply submitted before TPO and A.O. along with annexures is enclosed as per Annexure-E for your honors kind perusal. "In the annexed reply submitted to TPO dated 17.11.2020- Annexure

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 provisions. Similarly divided paid is not an item of expense but appropriation of profits. Thus, dividends are not subject to arm's length pricing principles. Hence Ld. TPO, Ld. A.O & Worthy CIT(A) are not justified to hold that once these items are reported in Form 3CEB as specified Domestic Transactions being any expenditure in respect of which

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 92C of the Act to the TPO for determining the arms length price in respect of specific domestic transaction undertaken by the assessee. The TPO after examining the transfer pricing adjustment and analyzing the specific domestic transaction with associated enterprises, proceeded to bench mark the power from eligible unit to non eligible unit specifically supply of electricity and steam

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)

section 1448 of the Act in pursuance of directions dated 26 September 2024 issued by Ld. Dispute Resolution Panel (DRP). In facts and circumstances of the case and in law, Ld. AO/ Transfer Pricing Officer (TPO) and Ld. DRP have: 1. erred in making transfer pricing adjustment of INR 166,00,63

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

63 r d meeting of the Genetic Engineering Approval Committee on the 8 th February 2006.The AO has contended that GSK Biologicals is carrying on vaccine development activity through these fixed place of business. That all intellectual ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys. 2007-08 to 2015-16 Page 13 of 120 property

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

63 r d meeting of the Genetic Engineering Approval Committee on the 8 th February 2006.The AO has contended that GSK Biologicals is carrying on vaccine development activity through these fixed place of business. That all intellectual ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys. 2007-08 to 2015-16 Page 13 of 120 property

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

63 r d meeting of the Genetic Engineering Approval Committee on the 8 th February 2006.The AO has contended that GSK Biologicals is carrying on vaccine development activity through these fixed place of business. That all intellectual ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys. 2007-08 to 2015-16 Page 13 of 120 property

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

63 r d meeting of the Genetic Engineering Approval Committee on the 8 th February 2006.The AO has contended that GSK Biologicals is carrying on vaccine development activity through these fixed place of business. That all intellectual ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys. 2007-08 to 2015-16 Page 13 of 120 property

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

63 r d meeting of the Genetic Engineering Approval Committee on the 8 th February 2006.The AO has contended that GSK Biologicals is carrying on vaccine development activity through these fixed place of business. That all intellectual ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys. 2007-08 to 2015-16 Page 13 of 120 property

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

63 r d meeting of the Genetic Engineering Approval Committee on the 8 th February 2006.The AO has contended that GSK Biologicals is carrying on vaccine development activity through these fixed place of business. That all intellectual ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys. 2007-08 to 2015-16 Page 13 of 120 property

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

63 r d meeting of the Genetic Engineering Approval Committee on the 8 th February 2006.The AO has contended that GSK Biologicals is carrying on vaccine development activity through these fixed place of business. That all intellectual ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys. 2007-08 to 2015-16 Page 13 of 120 property

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

63 r d meeting of the Genetic Engineering Approval Committee on the 8 th February 2006.The AO has contended that GSK Biologicals is carrying on vaccine development activity through these fixed place of business. That all intellectual ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys. 2007-08 to 2015-16 Page 13 of 120 property

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

63 r d meeting of the Genetic Engineering Approval Committee on the 8 th February 2006.The AO has contended that GSK Biologicals is carrying on vaccine development activity through these fixed place of business. That all intellectual ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys. 2007-08 to 2015-16 Page 13 of 120 property

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

63 r d meeting of the Genetic Engineering Approval Committee on the 8 th February 2006.The AO has contended that GSK Biologicals is carrying on vaccine development activity through these fixed place of business. That all intellectual ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys. 2007-08 to 2015-16 Page 13 of 120 property

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

63 r d meeting of the Genetic Engineering Approval Committee on the 8 th February 2006.The AO has contended that GSK Biologicals is carrying on vaccine development activity through these fixed place of business. That all intellectual ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys. 2007-08 to 2015-16 Page 13 of 120 property

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

63 r d meeting of the Genetic Engineering Approval Committee on the 8 th February 2006.The AO has contended that GSK Biologicals is carrying on vaccine development activity through these fixed place of business. That all intellectual ITA Nos.219 to 222,225 to 227,242, 228, 344/Chd/2017 ITA No.1495/Chd/2019 A.Ys. 2007-08 to 2015-16 Page 13 of 120 property

JANTA LAND PROMOTERS PVT LTD,MOHALI vs. THE PRINICIPAL COMMISSIONER OF INCOME TAX ,CHANDIGARH-1, CHANDIGARH

In the result, appeal of the Assessee is allowed

ITA 618/CHANDI/2025[2020-2021]Status: DisposedITAT Chandigarh29 Oct 2025AY 2020-2021
For Appellant: Shri Pankaj Bhalla, C.AFor Respondent: Shri Manav Bansal, CIT, DR
Section 143(3)Section 194Section 263Section 68

Pricing / MAT. 3. The Ld. AR had submitted that pursuant to the show cause notice issued by the Ld. PCIT the assessee had submitted the reply, which was reproduced at page 8 of the impugned order as under: 1) Issue No.2.1 at para 2 of the show cause notice: 2.1 The Assessing Officer(AO) wrongly allowed the Development Expense provision

MAXPORT INDIA PRIVATE LIMITED,CHANDIGARH vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,CHANDIGARH, CHANDIGARH

ITA 583/CHANDI/2023[2015-16]Status: DisposedITAT Chandigarh03 Mar 2025AY 2015-16
Section 127Section 132Section 153ASection 153D

63,212/- made by ld. AO u/s\n2(22)(e) received from SEPL”\n23. The brief facts relating to the issue are that during the assessment proceedings, the\nAssessing Officer (AO) observed that the assessee is substantial shareholder (48.48%)\nin M/s Scott Edil Pharmacia Limited (hereinafter referred to as \"SEPL\"). He further\nobserved that there were significant credit entries

M/S MAHAVIR TECHNO LTD.,,CHANDIGARH vs. ACIT, CRICLE, KURUKSHETRA

In the result, appeal of the Assessee is allowed

ITA 332/CHANDI/2019[2014-15]Status: DisposedITAT Chandigarh23 Feb 2021AY 2014-15
For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Ashok Khanna, Addl. CIT
Section 143(1)Section 234BSection 36(1)(iii)

transferred in the account of M/s Mahabir Agro Industry. The company has earned the profit on sale of goods and the assesee has not paid any interest to the trade creditors and even the sister concerns when there was a credit balance in their account. No interest has been charged from other trade debtors to whom sales were made because