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94 results for “capital gains”+ TP Methodclear

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Key Topics

Section 143(3)66Disallowance52Addition to Income51Transfer Pricing29Comparables/TP24Depreciation23Section 14A21Section 92C19Section 115J18

ACIT,CENTRAL CIRCLE -3(1), CHENNAI vs. CHENNAI PROPERTIES AND INVESTMENTS LTD , CHENNAI

In the result, the appeal filed by the assessee in ITA

ITA 310/CHNY/2022[2016-2017]Status: DisposedITAT Chennai31 Jan 2023AY 2016-2017

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri B. Ramakrishnan, FCAFor Respondent: ShriP. SajitKumar,JCIT
Section 132Section 139(4)Section 143(3)Section 2(47)(v)

capital gains tax in respect of remaining land measuring 13.5 acres for which no considerationhad been received and which stood cancelled and incapable of performance at present due to various orders passed by the Supreme Court and the High Court in PILs. Therefore, the appeals areallowed." 8.1 Even this issue of execution of GPA’s and on the basis

Showing 1–20 of 94 · Page 1 of 5

Section 14718
Deduction16
Section 144C(5)15

FAIZA HEMEED,CHENNAI vs. ITO, INTERNATIONAL TAXATION, WARD-1(2), CHENNAI

In the result, appeal filed by the assessee is allowed

ITA 187/CHNY/2019[2014-15]Status: DisposedITAT Chennai08 Jan 2021AY 2014-15

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita No.: 187/Chny/2019 िनधा"रण वष" / Assessment Year: 2014-15 Smt. Faiza Hameed, The Income Tax Officer, No.60, Veerabadran Street, V. International Taxation, Nungambakkam, Ward-1(2), Chennai – 600 034. Chennai. Pan: Abwph4868A (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Ms. S.Vidhya, F.C.A ""यथ" क" ओर से/Respondent By : Shri G.Johnson, Addl.Cit सुनवाई क" तार"ख/Date Of Hearing : 14.12.2020 घोषणा क" तार"ख/Date Of Pronouncement : 08.01.2021

For Appellant: Ms. S.Vidhya, F.C.A ""For Respondent: Shri G.Johnson, Addl.CIT
Section 139(1)Section 147Section 148Section 50C

capital gain will arise only for the asst. Year 2014-15, as the transfer deemed to have been completed only in this year.” 2.8. Having paid the Advance tax and fifing the Return in response to the notice u/s 148; and agreeing in writing during the course of assessment proceeding as above, the assessee can not take a ground that

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

ITA 2275/CHNY/2019[2010-11]Status: DisposedITAT Chennai05 Aug 2022AY 2010-11

Bench: Shri Mahavir Singhand Shri G. Manjunatha

For Appellant: Shri P. G. Sekar, C.A ""For Respondent: Dr. S. Palani Kumar,CIT
Section 143(3)

gains tax. 7. Per Contra, ld.CIT-DR stating that the brand value was created in the books of accounts of the partnership firm as on 30.04.2008 and this firm was converted into a Public Ltd. Co. i.e. the assessee company. He stated that the so called brand value was never existed in the books of the partnership firm V.V.Vanniaperumal & Sons

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

ITA 2278/CHNY/2019[2013-14]Status: DisposedITAT Chennai05 Aug 2022AY 2013-14

Bench: Shri Mahavir Singhand Shri G. Manjunatha

For Appellant: Shri P. G. Sekar, C.A ""For Respondent: Dr. S. Palani Kumar,CIT
Section 143(3)

gains tax. 7. Per Contra, ld.CIT-DR stating that the brand value was created in the books of accounts of the partnership firm as on 30.04.2008 and this firm was converted into a Public Ltd. Co. i.e. the assessee company. He stated that the so called brand value was never existed in the books of the partnership firm V.V.Vanniaperumal & Sons

M/S. V.V.VANNIAPERUMAL & SONS,VIRUDHUNAGAR vs. PCIT-2, CHENNAI, CHENNAI

In the result, the appeals of the assessee in ITA Nos

ITA 1765/CHNY/2019[2009-10]Status: DisposedITAT Chennai05 Aug 2022AY 2009-10

Bench: Shri Mahavir Singhand Shri G. Manjunatha

For Appellant: Shri P. G. Sekar, C.A ""For Respondent: Dr. S. Palani Kumar,CIT
Section 143(3)

gains tax. 7. Per Contra, ld.CIT-DR stating that the brand value was created in the books of accounts of the partnership firm as on 30.04.2008 and this firm was converted into a Public Ltd. Co. i.e. the assessee company. He stated that the so called brand value was never existed in the books of the partnership firm V.V.Vanniaperumal & Sons

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

ITA 2276/CHNY/2019[2011-12]Status: DisposedITAT Chennai05 Aug 2022AY 2011-12

Bench: Shri Mahavir Singhand Shri G. Manjunatha

For Appellant: Shri P. G. Sekar, C.A ""For Respondent: Dr. S. Palani Kumar,CIT
Section 143(3)

gains tax. 7. Per Contra, ld.CIT-DR stating that the brand value was created in the books of accounts of the partnership firm as on 30.04.2008 and this firm was converted into a Public Ltd. Co. i.e. the assessee company. He stated that the so called brand value was never existed in the books of the partnership firm V.V.Vanniaperumal & Sons

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

ITA 2281/CHNY/2019[2016-17]Status: DisposedITAT Chennai05 Aug 2022AY 2016-17

Bench: Shri Mahavir Singhand Shri G. Manjunatha

For Appellant: Shri P. G. Sekar, C.A ""For Respondent: Dr. S. Palani Kumar,CIT
Section 143(3)

gains tax. 7. Per Contra, ld.CIT-DR stating that the brand value was created in the books of accounts of the partnership firm as on 30.04.2008 and this firm was converted into a Public Ltd. Co. i.e. the assessee company. He stated that the so called brand value was never existed in the books of the partnership firm V.V.Vanniaperumal & Sons

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

ITA 2279/CHNY/2019[2014-15]Status: DisposedITAT Chennai05 Aug 2022AY 2014-15

Bench: Shri Mahavir Singhand Shri G. Manjunatha

For Appellant: Shri P. G. Sekar, C.A ""For Respondent: Dr. S. Palani Kumar,CIT
Section 143(3)

gains tax. 7. Per Contra, ld.CIT-DR stating that the brand value was created in the books of accounts of the partnership firm as on 30.04.2008 and this firm was converted into a Public Ltd. Co. i.e. the assessee company. He stated that the so called brand value was never existed in the books of the partnership firm V.V.Vanniaperumal & Sons

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

ITA 2277/CHNY/2019[2012-13]Status: DisposedITAT Chennai05 Aug 2022AY 2012-13

Bench: Shri Mahavir Singhand Shri G. Manjunatha

For Appellant: Shri P. G. Sekar, C.A ""For Respondent: Dr. S. Palani Kumar,CIT
Section 143(3)

gains tax. 7. Per Contra, ld.CIT-DR stating that the brand value was created in the books of accounts of the partnership firm as on 30.04.2008 and this firm was converted into a Public Ltd. Co. i.e. the assessee company. He stated that the so called brand value was never existed in the books of the partnership firm V.V.Vanniaperumal & Sons

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

ITA 2280/CHNY/2019[2015-16]Status: DisposedITAT Chennai05 Aug 2022AY 2015-16

Bench: Shri Mahavir Singhand Shri G. Manjunatha

For Appellant: Shri P. G. Sekar, C.A ""For Respondent: Dr. S. Palani Kumar,CIT
Section 143(3)

gains tax. 7. Per Contra, ld.CIT-DR stating that the brand value was created in the books of accounts of the partnership firm as on 30.04.2008 and this firm was converted into a Public Ltd. Co. i.e. the assessee company. He stated that the so called brand value was never existed in the books of the partnership firm V.V.Vanniaperumal & Sons

BANCA SELLA S.P.A. CHENNAI BRANCH (IT DIVISION),CHENNAI vs. DCIT, CHENNAI

In the result, the appeal of the assessee in ITA

ITA 417/CHNY/2015[2010-11]Status: DisposedITAT Chennai15 Sept 2016AY 2010-11

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A. No.398/Mds/2015 "नधा"रण वष" /Assessment Year : 2010-2011

For Appellant: Shri. Percy PardiwallaFor Respondent: Smt. Parminder Kaur, CIT
Section 142(1)Section 143(1)Section 143(3)Section 2Section 28Section 5OSection 92C

Gains. 3.8 In the result, the appeal of the Revenue in ITA No.557/Mds/2015 of assessment 2010-2011 is dismissed. C.O.No.45/Mds/2015 in ITA No.557/Mds/2015:- The 4. assessee has filed the Cross objection and raised the following grounds:- 1 The learned AO/TPO/DRP ought to have appreciated that the customer of the assessee had decided to carry on business by itself through

SELLA SYNERGY INDIA PVT. LTD.,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal of the assessee in ITA

ITA 398/CHNY/2015[2010-11]Status: DisposedITAT Chennai15 Sept 2016AY 2010-11

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A. No.398/Mds/2015 "नधा"रण वष" /Assessment Year : 2010-2011

For Appellant: Shri. Percy PardiwallaFor Respondent: Smt. Parminder Kaur, CIT
Section 142(1)Section 143(1)Section 143(3)Section 2Section 28Section 5OSection 92C

Gains. 3.8 In the result, the appeal of the Revenue in ITA No.557/Mds/2015 of assessment 2010-2011 is dismissed. C.O.No.45/Mds/2015 in ITA No.557/Mds/2015:- The 4. assessee has filed the Cross objection and raised the following grounds:- 1 The learned AO/TPO/DRP ought to have appreciated that the customer of the assessee had decided to carry on business by itself through

DCIT, CHENNAI vs. SELLA SYNERGY INDIA PVT LTD., CHENNAI

In the result, the appeal of the assessee in ITA

ITA 557/CHNY/2015[2010-11]Status: DisposedITAT Chennai15 Sept 2016AY 2010-11

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A. No.398/Mds/2015 "नधा"रण वष" /Assessment Year : 2010-2011

For Appellant: Shri. Percy PardiwallaFor Respondent: Smt. Parminder Kaur, CIT
Section 142(1)Section 143(1)Section 143(3)Section 2Section 28Section 5OSection 92C

Gains. 3.8 In the result, the appeal of the Revenue in ITA No.557/Mds/2015 of assessment 2010-2011 is dismissed. C.O.No.45/Mds/2015 in ITA No.557/Mds/2015:- The 4. assessee has filed the Cross objection and raised the following grounds:- 1 The learned AO/TPO/DRP ought to have appreciated that the customer of the assessee had decided to carry on business by itself through

RAMAKRISHNAN PRABHU JYOTHI,,COIMBATORE vs. ACOT, NCC-5, , COIMBATORE

In the result the appeal is dismissed

ITA 690/CHNY/2020[2016-17]Status: DisposedITAT Chennai23 Aug 2024AY 2016-17
Section 142ASection 142A(1)Section 142A(6)Section 143(1)Section 153Section 250

gains. The second limb of the statute e.i “purchase”\nhas not been fulfilled. The assesse is consistently harping on the issue that\nas it has purchased the impugned immovable property from Jeypore Sugar\nCompany Limited(JSC) and has paid the whole amount of consideration\namounting to Rs.141 Crores app. and has obtained the possession, there\nmay not be any doubt

FLSMIDTH PRIVATE LIMITED,CHENNAI vs. PCIT- 1, CHENNAI

In the result, the appeal filed by the assessee is dismissed

ITA 1636/CHNY/2024[2014-15]Status: DisposedITAT Chennai10 Dec 2024AY 2014-15

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.1636/Chny/2024 िनधा:रण वष: /Assessment Year: 2014-15 M/S. Flsmidth Pvt. Ltd., The Principal Commissioner Of No.34, Egatoor, Kelambakkam Vs. Income Tax-1, Rajiv Gandhi Salai, Chennai. Chennai – 603 103. [Pan: Aaacf 4997N]

For Appellant: Shri S.P. Chidambaram, AdvocateFor Respondent: Shri Nilay Baran Som, CIT
Section 143(3)Section 147Section 14ASection 263

TP adjustment of Rs.3,71,56,870/- and disallowance u/s. 14A of the Act of Rs.31,35,846/-. Subsequently, the A.O has reopened the assessment u/s.147 of the Act, but accepted the return of income at Rs.57,25,24,130/- without making any addition. The A.O had reopened the assessment on the following grounds: i. The assessee has claimed capital

ASHOK LEYLAND LTD.,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal of the Revenue in ITA

ITA 2834/CHNY/2014[1995-96]Status: DisposedITAT Chennai23 Sept 2016AY 1995-96

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A. Nos.2825, 2826 & 2827/Mds/2014 "नधा"रण वष" /Assessment Years : 2005-06, 2006-07 & 2007-2008. The Deputy Commissioner Of M/S. Ashok Leyland Ltd, Income Tax, Vs. No.1, Sardar Patel Road, Large Taxpayer Unit -Ii, Guindy, Chennai 600 101. Chennai 600 032. [Pan Aaaca 4651L] (Department) (Assessee )

For Appellant: Shri. Vikram Vijayaraghavan, AdvocateFor Respondent: Shri. Arun C. Bharath, IRS, CIT
Section 35D(2)Section 35D(2)(c)

TP adjustment in view of the order of Tribunal in the case of Redington India Ltd vs. ACIT 155 ITD 873 (Chennai). 30.2 We have heard both the sides. In our opinion the plea of the assessee is justified. Accordingly, we hold that the assessee is entitled for volume discount in respect of sale of spare parts. Regarding guarantee commission

DCIT, CHENNAI vs. ASHOK LEYLAND LTD., CHENNAI

In the result, the appeal of the Revenue in ITA

ITA 2825/CHNY/2014[2005-06]Status: DisposedITAT Chennai23 Sept 2016AY 2005-06

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A. Nos.2825, 2826 & 2827/Mds/2014 "नधा"रण वष" /Assessment Years : 2005-06, 2006-07 & 2007-2008. The Deputy Commissioner Of M/S. Ashok Leyland Ltd, Income Tax, Vs. No.1, Sardar Patel Road, Large Taxpayer Unit -Ii, Guindy, Chennai 600 101. Chennai 600 032. [Pan Aaaca 4651L] (Department) (Assessee )

For Appellant: Shri. Vikram Vijayaraghavan, AdvocateFor Respondent: Shri. Arun C. Bharath, IRS, CIT
Section 35D(2)Section 35D(2)(c)

TP adjustment in view of the order of Tribunal in the case of Redington India Ltd vs. ACIT 155 ITD 873 (Chennai). 30.2 We have heard both the sides. In our opinion the plea of the assessee is justified. Accordingly, we hold that the assessee is entitled for volume discount in respect of sale of spare parts. Regarding guarantee commission

DCIT, CHENNAI vs. ASHOK LEYLAND LTD., CHENNAI

In the result, the appeal of the Revenue in ITA

ITA 2827/CHNY/2014[2007-08]Status: DisposedITAT Chennai23 Sept 2016AY 2007-08

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A. Nos.2825, 2826 & 2827/Mds/2014 "नधा"रण वष" /Assessment Years : 2005-06, 2006-07 & 2007-2008. The Deputy Commissioner Of M/S. Ashok Leyland Ltd, Income Tax, Vs. No.1, Sardar Patel Road, Large Taxpayer Unit -Ii, Guindy, Chennai 600 101. Chennai 600 032. [Pan Aaaca 4651L] (Department) (Assessee )

For Appellant: Shri. Vikram Vijayaraghavan, AdvocateFor Respondent: Shri. Arun C. Bharath, IRS, CIT
Section 35D(2)Section 35D(2)(c)

TP adjustment in view of the order of Tribunal in the case of Redington India Ltd vs. ACIT 155 ITD 873 (Chennai). 30.2 We have heard both the sides. In our opinion the plea of the assessee is justified. Accordingly, we hold that the assessee is entitled for volume discount in respect of sale of spare parts. Regarding guarantee commission

GAMESA RENEWABLE PRIVATE LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, both the appeals of the assessee are partly allowed for statistical purposes

ITA 376/CHNY/2017[2012-13]Status: DisposedITAT Chennai13 Nov 2017AY 2012-13

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

For Appellant: Shri B.Ramakrishnan, FCA &For Respondent: Smt. Vijayalakshmi, CIT,D.R
Section 143(3)Section 144C(1)Section 144C(5)

gain experience. Towards empowering the project managers, Gamesa-Spain helps the company in providing suitable training to the staff. Gamesa Guideline Code: GDE-TEC-004 Short circuit claculations Previous code: N/A Edition:1 Language : Page :1 of 133 Date:14/02/2012 Security : Public Rating The above guidelines are explaining how to proceed with the calculations of short-circuits currents

GAMESA RENEWABLE PRIVATE LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, both the appeals of the assessee are partly allowed for statistical purposes

ITA 1420/CHNY/2017[2011-12]Status: DisposedITAT Chennai13 Nov 2017AY 2011-12

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

For Appellant: Shri B.Ramakrishnan, FCA &For Respondent: Smt. Vijayalakshmi, CIT,D.R
Section 143(3)Section 144C(1)Section 144C(5)

gain experience. Towards empowering the project managers, Gamesa-Spain helps the company in providing suitable training to the staff. Gamesa Guideline Code: GDE-TEC-004 Short circuit claculations Previous code: N/A Edition:1 Language : Page :1 of 133 Date:14/02/2012 Security : Public Rating The above guidelines are explaining how to proceed with the calculations of short-circuits currents