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53 results for “transfer pricing”+ Section 127clear

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Key Topics

Addition to Income22Disallowance21Section 153A20Section 13218Section 80I16Section 143(3)14Section 153C13Section 3512Section 142(1)9

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

price or payment in kind or adjustment towards debt or for monetary\nconsideration. That the issue of ownership and possession nowhere\nform part of the provision and concept of transfer is alien to it.\n7.\nThe CIT (Appeals) and AO failed to take note of judgment in CIT vs\nDr.Laxmichand Narpal Nagda (1995 211 ITR 804 (Bom) wherein

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. ASHOK LEYLAND LIMITED, CHENNAI

Showing 1–20 of 53 · Page 1 of 3

Section 2508
Deduction7
Undisclosed Income5

In the result, appeal filed by the assessee is partly allowed and the

ITA 1663/CHNY/2024[2019-20]Status: DisposedITAT Chennai07 Jul 2025AY 2019-20

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.R. VijayaraghavanFor Respondent: Ms.Ann Marry Baby, CIT
Section 14ASection 92C

transfer pricing provisions. Accordingly, the first plea of the assessee is hereby rejected. 5.3 The next issue now to be adjudicated is the ALP value of the guarantee commission. In this regard, the Ld. AR has relied on the quote provided by Bank(s) in which they have proposed to extend bank guarantee at 0.325% and has urged that

SAMARJIT SINGH CHABRA,CHENNAI vs. ITO NON CORPORATE WARD 14(1), CHENNAI

In the result, all the appeals filed by the assessee in ITA No

ITA 1624/CHNY/2018[2009-10]Status: DisposedITAT Chennai31 Jul 2024AY 2009-10

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1623, 1624, 1625 & 1646/Chny/2018 िनधा"रण वष"/Assessment Years: 2007-08, 2009-10, 2010-11 & 2008-09 & W.T.A. Nos. 43 & 44/Chny/2018 Assessment Years: 2007-08, 2008-09 Shri Samarijit Singh Chabra, Vs. The Income Tax Officer/ No. K-10, Sangath Apartments, Wealth Tax Officer, Mgr Nagar, Velachery, Non Corporate Ward – 14(1), Chennai 600 042. Chennai. [Pan: Bfops1703Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.05.2024 घोषणा की तारीख /Date Of Pronouncement : 31.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Income Tax Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 26.02.2018 Passed By The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai For The Assessment Years 2007-08, 2009-10, 2010-11 & 2008-09. 2. Since, Issues Raised In All The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Shri P. Sajit Kumar, JCIT
Section 142(1)

price was met out of sale proceeds of land at Kammaguda, Turkyamjal village, inherited by the assessee from his mother long back, during the Financial Year 2006-07. It is apt to mention that the Assessing Officer herself has by her order dated 03.03.2015 U/s144 r.w.s 147of the Income Tax Act, for the Ay 2007-08, has levied capital gains

SAMARJIT SINGH CHABRA,CHENNAI vs. ITO NON CORPORATE WARD 14(1), CHENNAI

In the result, all the appeals filed by the assessee in ITA No

ITA 1646/CHNY/2018[2008-09]Status: DisposedITAT Chennai31 Jul 2024AY 2008-09

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1623, 1624, 1625 & 1646/Chny/2018 िनधा"रण वष"/Assessment Years: 2007-08, 2009-10, 2010-11 & 2008-09 & W.T.A. Nos. 43 & 44/Chny/2018 Assessment Years: 2007-08, 2008-09 Shri Samarijit Singh Chabra, Vs. The Income Tax Officer/ No. K-10, Sangath Apartments, Wealth Tax Officer, Mgr Nagar, Velachery, Non Corporate Ward – 14(1), Chennai 600 042. Chennai. [Pan: Bfops1703Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.05.2024 घोषणा की तारीख /Date Of Pronouncement : 31.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Income Tax Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 26.02.2018 Passed By The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai For The Assessment Years 2007-08, 2009-10, 2010-11 & 2008-09. 2. Since, Issues Raised In All The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Shri P. Sajit Kumar, JCIT
Section 142(1)

price was met out of sale proceeds of land at Kammaguda, Turkyamjal village, inherited by the assessee from his mother long back, during the Financial Year 2006-07. It is apt to mention that the Assessing Officer herself has by her order dated 03.03.2015 U/s144 r.w.s 147of the Income Tax Act, for the Ay 2007-08, has levied capital gains

SAMARJIT SINGH CHABRA,CHENNAI vs. ITO NON CORPORATE WARD 14(1), CHENNAI

In the result, all the appeals filed by the assessee in ITA No

ITA 1625/CHNY/2018[2010-11]Status: DisposedITAT Chennai31 Jul 2024AY 2010-11

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1623, 1624, 1625 & 1646/Chny/2018 िनधा"रण वष"/Assessment Years: 2007-08, 2009-10, 2010-11 & 2008-09 & W.T.A. Nos. 43 & 44/Chny/2018 Assessment Years: 2007-08, 2008-09 Shri Samarijit Singh Chabra, Vs. The Income Tax Officer/ No. K-10, Sangath Apartments, Wealth Tax Officer, Mgr Nagar, Velachery, Non Corporate Ward – 14(1), Chennai 600 042. Chennai. [Pan: Bfops1703Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.05.2024 घोषणा की तारीख /Date Of Pronouncement : 31.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Income Tax Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 26.02.2018 Passed By The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai For The Assessment Years 2007-08, 2009-10, 2010-11 & 2008-09. 2. Since, Issues Raised In All The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Shri P. Sajit Kumar, JCIT
Section 142(1)

price was met out of sale proceeds of land at Kammaguda, Turkyamjal village, inherited by the assessee from his mother long back, during the Financial Year 2006-07. It is apt to mention that the Assessing Officer herself has by her order dated 03.03.2015 U/s144 r.w.s 147of the Income Tax Act, for the Ay 2007-08, has levied capital gains

SAMARJIT SINGH CHABRA,CHENNAI vs. ITO NON CORPORATE WARD 14(1), CHENNAI

In the result, all the appeals filed by the assessee in ITA No

ITA 1623/CHNY/2018[2007-08]Status: DisposedITAT Chennai31 Jul 2024AY 2007-08

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1623, 1624, 1625 & 1646/Chny/2018 िनधा"रण वष"/Assessment Years: 2007-08, 2009-10, 2010-11 & 2008-09 & W.T.A. Nos. 43 & 44/Chny/2018 Assessment Years: 2007-08, 2008-09 Shri Samarijit Singh Chabra, Vs. The Income Tax Officer/ No. K-10, Sangath Apartments, Wealth Tax Officer, Mgr Nagar, Velachery, Non Corporate Ward – 14(1), Chennai 600 042. Chennai. [Pan: Bfops1703Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.05.2024 घोषणा की तारीख /Date Of Pronouncement : 31.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Income Tax Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 26.02.2018 Passed By The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai For The Assessment Years 2007-08, 2009-10, 2010-11 & 2008-09. 2. Since, Issues Raised In All The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Shri P. Sajit Kumar, JCIT
Section 142(1)

price was met out of sale proceeds of land at Kammaguda, Turkyamjal village, inherited by the assessee from his mother long back, during the Financial Year 2006-07. It is apt to mention that the Assessing Officer herself has by her order dated 03.03.2015 U/s144 r.w.s 147of the Income Tax Act, for the Ay 2007-08, has levied capital gains

ASSISTANT COMMISSIONER OF INCOME-TAX, MADURAI vs. RAMASUBBU MINNALKODI, TIRUNELVELI

In the result, the appeal of the Revenue is dismissed

ITA 1632/CHNY/2025[2020-21]Status: DisposedITAT Chennai07 Oct 2025AY 2020-21
Section 133ASection 139(1)Section 142(1)Section 143(2)Section 143(3)

price of Rs.1,450/-. He further stated\nthat it was the regular practice of the assessee to issue bills for a lower value.\nIn her sworn statement recorded during the survey, the assessee admitted the\ntotal turnover for the relevant assessment year, as on the date of survey, at\nRs.6,64,76,379/-, and further agreed to offer 8% thereof

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, TRICHY, TRICHY vs. NEELARAJ VINOTH, PERAMBALUR

In the result, the appeal of the assessee is dismissed

ITA 1982/CHNY/2024[2017-18]Status: DisposedITAT Chennai18 Feb 2025AY 2017-18
For Appellant: Shri. G. Baskar, Advocate &For Respondent: Shri. R. Clement Ramesh Kumar, CIT
Section 143(3)Section 153CSection 153DSection 154Section 234A

127 Taxman\n523, is relied upon, the Hon'ble Gujarat High Court has held that the\nonus of the assessee (in whose books of account credit appears) stads\nfully discharged if the identity of the creditor is established\nand actual receipt of money from such creditor is proved. In case, the\nAssessing Officer is dissatisfied about the source of cash

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, COIMBATORE vs. M/S RPP INFRA PROJECTS LIMITED, ERODE

In the result, all these four appeals filed by the Revenue are dismissed

ITA 333/CHNY/2021[2012-13]Status: DisposedITAT Chennai16 May 2025AY 2012-13

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunatha

For Appellant: Mr. Shivanand K. Kalakeri, CITFor Respondent: Mr. N.Arjun Raj, Advocate
Section 250(1)Section 80Section 80I

127 days in filing three appeals for AYs 2012-13, 2013-14, 2017-18. Considering the reasons stated in the affidavits by the Revenue, we condone the delay and treat the reasons as ‘sufficient cause’ and admit these appeals for adjudication. 3. The common grounds raised by Revenue for AY 2012-13, 2013-14 & 2017-18 read as under

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, COIMBATORE vs. M/S. RP INFRA PROJECTS LIMITED, ERODE

In the result, all these four appeals filed by the Revenue are dismissed

ITA 335/CHNY/2021[2017-18]Status: DisposedITAT Chennai16 May 2025AY 2017-18

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunatha

For Appellant: Mr. Shivanand K. Kalakeri, CITFor Respondent: Mr. N.Arjun Raj, Advocate
Section 250(1)Section 80Section 80I

127 days in filing three appeals for AYs 2012-13, 2013-14, 2017-18. Considering the reasons stated in the affidavits by the Revenue, we condone the delay and treat the reasons as ‘sufficient cause’ and admit these appeals for adjudication. 3. The common grounds raised by Revenue for AY 2012-13, 2013-14 & 2017-18 read as under

DCIT , COIMBATORE vs. M/S RPP INFRA PROJECTS LIMITED , ERODE

In the result, all these four appeals filed by the Revenue are\ndismissed

ITA 847/CHNY/2022[2016-2017]Status: DisposedITAT Chennai16 May 2025AY 2016-2017
Section 250(1)Section 80Section 80I

127 days in filing three appeals\nfor AYs 2012-13, 2013-14, 2017-18. Considering the reasons stated\nin the affidavits by the Revenue, we condone the delay and treat the\nreasons as 'sufficient cause' and admit these appeals for\nadjudication.\nITA Nos.333 to 335Chny/2021 &\n847/Chny/2022\n3. The common grounds raised by Revenue for AY 2012-13,\n2013

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, COIMBATORE vs. M/S RPP INFRA PROJECTS LIMITED, ERODE

In the result, all these four appeals filed by the Revenue are\ndismissed

ITA 334/CHNY/2021[2013-14]Status: DisposedITAT Chennai16 May 2025AY 2013-14
Section 250(1)Section 80Section 80I

127 days in filing three appeals\nfor AYs 2012-13, 2013-14, 2017-18. Considering the reasons stated\nin the affidavits by the Revenue, we condone the delay and treat the\nreasons as 'sufficient cause' and admit these appeals for\nadjudication.\nITA Nos.333 to 335Chny/2021 &\n847/Chny/2022\n3. The common grounds raised by Revenue for AY 2012-13,\n2013

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. MOHANLAL JEWELLERS PRIVATE LIMITED, CHENNAI

ITA 1394/CHNY/2025[2018-19]Status: DisposedITAT Chennai26 Sept 2025AY 2018-19
For Appellant: Mr. D. Anand, AdvocateFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 132Section 143(3)Section 153A

transfer entries are as below: -\n\nITA Nos.1178 to 1182/Chny/2025 &\nITA Nos.1393 to 1397/Chny/2025 \n(AYs: 2017-18 to 2021-22)\nM/s. Mohanlal Jewellers Pvt. Ltd\n\n::73 :: \n\nAO, both Shri Kothari and Shri Khatri had admitted that, the entries in\nthis ledger was also unaccounted for and therefore the AO quantified the\n‘Vatav’ income from this

DCIT CENTRAL CIRCLE 2(1), CHENAI vs. C.VIJAYA BASKAR, PUDUKOTTAI

In the result, ITA Nos.695 to 702/Chny/2023 stands dismissed

ITA 696/CHNY/2023[2012-13]Status: DisposedITAT Chennai28 Feb 2025AY 2012-13
For Appellant: S/Shri Nithyaesh Natraj, Vaibav R. VenkateshFor Respondent: Shri A.P. Srinivas (Sr. Standing Counsel for
Section 143(3)

price. \nThe Ld. CIT(A) re-worked the same and excluded the profit element from \nvaluation. It could be seen that after excluding the profit element, the \nvaluation would come down to Rs.412.29 Lacs as against Rs.435.54 \n\n24\n\nLacs as already disclosed by the assessee. In such a case, the addition \nof Rs.38.86 Lacs and Rs.22.34 Lacs

NEELARAJ VINOTH,PERAMBALUR vs. ACIT, CC-2, , TRICHY

In the result, the appeal of the revenue is dismissed and the CO filed by the assessee is dismissed

ITA 2119/CHNY/2024[2017-18]Status: DisposedITAT Chennai18 Feb 2025AY 2017-18

Bench: Shri George George K, Hon’Ble & Shri S.R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 1982/Chny/2024 & C.O.No. 60/Chny/2024 िनधा"रण वष" / Assessment Year: 2017-18 Assistant Commissioner Of Neelaraj Vinoth, Income Tax, V. 274-C, Thuraiyur Road, Central Circle -2, Perambalur – 621 212, Trichy. Tamilnadu. [Pan: Ajupv-3588-M] (अपीलाथ"/Appellant) (Respondent/Cross Objector) आयकर अपील सं./Ita No.: 2119/Chny/2024 िनधा"रण वष" / Assessment Year: 2017-18 Neelaraj Vinoth, Assistant Commissioner Of 274-C, Thuraiyur Road, V. Income Tax, Perambalur – 621 212, Central Circle -2, Tamilnadu. Trichy. [Pan: Ajupv-3588-M] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri. G. Baskar, Advocate &For Respondent: Shri. R. Clement Ramesh Kumar, CIT
Section 143(3)Section 153CSection 153DSection 154Section 234A

127 Taxman 523, is relied upon, the Hon'ble Gujarat High Court has held that the onus of the assessee (in whose books of account credit appears) stands fully discharged if the identity of the creditor is established and actual receipt of money from such creditor is proved. In case, the Assessing Officer is dissatisfied about the source of cash

PARRY INFRASTRUCTURE CO P LTD. ,CHENNAI vs. DCIT CORPORATE CIRCLE 5(1) , CHENNAI

In the result, the appeal filed by the assessee is partly-allowed

ITA 1653/CHNY/2019[2013-14]Status: DisposedITAT Chennai03 Jul 2024AY 2013-14

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri Philip George, AdvocateFor Respondent: Shri Nilay Baran Som, CIT-DR
Section 143(2)Section 143(3)Section 14A

127,03,79,840 10,28,85,610 The CIT(A) asked for information and assessee filed the following documents:- S.No. Particulars Date of agreement 1 Power of attorney given by M/s. Tube Investments 22.06.2010 India Ltd. and EID Parry India Ltd., in favour of M/s. Parry Infrastructure Co Pvt Ltd (the appellant) 2 Joint Development Agreement 24.11.2010 3 Supplementary

SAME DEUTZ FAHR ITALIA SPA,ITALY vs. ASSISTANT COMMISSIONER, CHENNAI

In the result the appeal of the assessee is allowed

ITA 937/CHNY/2024[AY 2016-17]Status: DisposedITAT Chennai30 Jan 2025

Bench: Shri Aby T Varkey, Hon’Ble & Shri S.R.Raghunatha, Hon’Ble

For Appellant: Shri. S.P. Chidambaram, AdvocateFor Respondent: Ms. R. Anita, Addl. CIT
Section 147Section 148Section 250o

price. Further, on account of the above costs, the dealer claims reimbursements from the assessee and then the assessee claims reimbursement from SAME India for the cost incurred by the dealer. It is further to be noted that transporting the product from Italy to India for servicing will not be an economically viable option and hence SAME India has requested

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), CHENNAI, CHENNAI vs. RAMANATHAN VISWANATHAN, CHENNAI

In the result, all appeals filed by the assessee are allowed and the appeals of the Revenue are dismissed

ITA 1556/CHNY/2025[2016]Status: DisposedITAT Chennai22 Jan 2026

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Shri. V. Naga PrasadFor Respondent: Smt. E. Pavuna Sundari
Section 132Section 139Section 142(1)Section 153ASection 153CSection 250

transfer monies to the bank account(s) of his thirty eight (38) firms, which Shri CPA would withdraw in cash and hand over to the assessee. Shri CPA however expressed his unknowingness to the manner and mode in which the coal companies would allegedly pay monies to Shri PLA but submitted that somehow he would receive the monies

R.VISWANATHAN,CHENNAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4),, CHENNAI

ITA 1324/CHNY/2025[2017-18]Status: DisposedITAT Chennai22 Jan 2026AY 2017-18
For Appellant: Shri. V. Naga PrasadFor Respondent: Smt. E. Pavuna Sundari
Section 139Section 142(1)Section 153ASection 153CSection 250

transfer monies to the bank account(s) of his\nthirty eight (38) firms, which Shri CPA would withdraw in cash and hand\nover to the assessee. Shri CPA however expressed his unknowingness to\nthe manner and mode in which the coal companies would allegedly pay\nmonies to Shri PLA but submitted that somehow he would receive the\nmonies

R.VISWANATHAN,CHENNAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), CHENNAI

ITA 1323/CHNY/2025[2016-17]Status: DisposedITAT Chennai22 Jan 2026AY 2016-17
For Appellant: Shri. V. Naga PrasadFor Respondent: Smt. E. Pavuna Sundari
Section 139Section 142(1)Section 153ASection 153CSection 250

transfer monies to the bank account(s) of his\nthirty eight (38) firms, which Shri CPA would withdraw in cash and hand\nover to the assessee. Shri CPA however expressed his unknowingness to\nthe manner and mode in which the coal companies would allegedly pay\nmonies to Shri PLA but submitted that somehow he would receive the\nmonies