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33 results for “transfer pricing”+ Section 194Cclear

Sorted by relevance

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Key Topics

Section 194H30Section 13924Section 153A20Section 201(1)16Addition to Income15Disallowance14TDS13Section 13212Section 1112Section 143(3)

DCIT, CHENNAI vs. PARRYWARE ROCA PVT. LTD., CHENNAI

In the result, I.T.A. Nos

ITA 1169/CHNY/2014[2009-10]Status: DisposedITAT Chennai18 Dec 2015AY 2009-10

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No.586/Mds/2014 & आयकर अपील सं./Ita No.610/Mds/2015 "नधा"रण वष" / Assessment Years : 2009-10 & 2010-11

For Appellant: Shri Raghunathan Sampath, AdvocateFor Respondent: Dr. Milind Madhukar Bhusari, CIT

Transfer Pricing Officer or Dispute Resolution Panel, this Tribunal is of the considered opinion that the matter needs to be re-examined. Accordingly, the orders of the Assessing Officer are set aside and the Assessing Officer shall refer the matter again to the Dispute Resolution Panel. The Dispute Resolution Panel shall examine the agreement between the parties and other transactions

ROCA BATHROOM PRODUCTS PRIVATE LIMITED,CHENNAI vs. JCIT, CHENNAI

In the result, I.T.A. Nos

ITA 586/CHNY/2014[2009-10]Status: DisposedITAT Chennai

Showing 1–20 of 33 · Page 1 of 2

8
Section 378
Survey u/s 133A8
18 Dec 2015
AY 2009-10

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No.586/Mds/2014 & आयकर अपील सं./Ita No.610/Mds/2015 "नधा"रण वष" / Assessment Years : 2009-10 & 2010-11

For Appellant: Shri Raghunathan Sampath, AdvocateFor Respondent: Dr. Milind Madhukar Bhusari, CIT

Transfer Pricing Officer or Dispute Resolution Panel, this Tribunal is of the considered opinion that the matter needs to be re-examined. Accordingly, the orders of the Assessing Officer are set aside and the Assessing Officer shall refer the matter again to the Dispute Resolution Panel. The Dispute Resolution Panel shall examine the agreement between the parties and other transactions

VNC STEEL DISTRIBUTORS,,KARUR vs. DCIT, CIRCLE-1(1), TRICHY

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

ITA 1937/CHNY/2024[2017-18]Status: DisposedITAT Chennai14 Nov 2024AY 2017-18

Bench: Shri Mahavir Singh, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 1937/Chny/2024 & Stay Petition No: 40/Chny/2024 [In Ita No: 1937/Chny/2024)] िनधा"रणवष" / Assessment Year: 2017-18 Vnc Steel Distributors, Deputy Commissioner Of No.2, Industrial Estate, V. Income Tax, S. Vellalapatti, Circle -1(1), Karur – 639 004. Trichy. [Pan: Aadfv-9137-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. Abhinov Vaidyanathan, Advocate ""यथ"क"ओरसे/Respondent By : Shri. R. Clement Ramesh Kumar, Cit सुनवाई क" तारीख/Date Of Hearing : 21.08.2024 घोषणा क" तारीख/Date Of Pronouncement : 14.11.2024 आदेश /O R D E R

For Appellant: Shri. Abhinov Vaidyanathan, AdvocateFor Respondent: Shri. R. Clement Ramesh Kumar, CIT
Section 194CSection 194HSection 2Section 250Section 253(1)Section 30Section 40

price, business, training, etc.. Therefore, the contention of the assessee that dealer incentive scheme of the assessee are on principal-to principal basis, does not stand to the test of facts and clauses of the dealer appointment letters. In normal situation of principal-to principal relationship one cannot control the other. However, in the present case, the assessee exercises

VODAFONE MOBILE SERVICES LIMITED,COIMBATORE vs. DCIT, COIMBATORE

In the result, all the appeal filed by the assessee are partly allowed for statistical purposes

ITA 755/CHNY/2017[2014-15]Status: DisposedITAT Chennai21 Sept 2017AY 2014-15

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

For Appellant: Shri Salil Kapoor, Advocate
Section 131Section 133ASection 194HSection 201Section 201(1)

transferred to the distributor’. 45. Taking into account the provisions of Section 182 of the Contract Act and the arrangement which has been entered into between the company and the distributor and taking into account the provisions of Section 194H, the Tribunal while considering the evidence on record, in our considered opinion, has misdirected itself in considering the case from

VODAFONE CELLULAR LIMITED,COIMBATORE vs. DCIT, COIMBATORE

In the result, all the appeal filed by the assessee are partly allowed for statistical purposes

ITA 2804/CHNY/2014[2011-12]Status: DisposedITAT Chennai21 Sept 2017AY 2011-12

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

For Appellant: Shri Salil Kapoor, Advocate
Section 131Section 133ASection 194HSection 201Section 201(1)

transferred to the distributor’. 45. Taking into account the provisions of Section 182 of the Contract Act and the arrangement which has been entered into between the company and the distributor and taking into account the provisions of Section 194H, the Tribunal while considering the evidence on record, in our considered opinion, has misdirected itself in considering the case from

VODAFONE MOBILE SERVICES LIMITED,COIMBATORE vs. DCIT, COIMBATORE

In the result, all the appeal filed by the assessee are partly allowed for statistical purposes

ITA 754/CHNY/2017[2012-13]Status: DisposedITAT Chennai21 Sept 2017AY 2012-13

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

For Appellant: Shri Salil Kapoor, Advocate
Section 131Section 133ASection 194HSection 201Section 201(1)

transferred to the distributor’. 45. Taking into account the provisions of Section 182 of the Contract Act and the arrangement which has been entered into between the company and the distributor and taking into account the provisions of Section 194H, the Tribunal while considering the evidence on record, in our considered opinion, has misdirected itself in considering the case from

VODAFONE CELLULAR LIMITED,COIMBATORE vs. ACIT, COIMBATORE

In the result, all the appeal filed by the assessee are partly allowed for statistical purposes

ITA 1644/CHNY/2014[2010-11]Status: DisposedITAT Chennai21 Sept 2017AY 2010-11

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

For Appellant: Shri Salil Kapoor, Advocate
Section 131Section 133ASection 194HSection 201Section 201(1)

transferred to the distributor’. 45. Taking into account the provisions of Section 182 of the Contract Act and the arrangement which has been entered into between the company and the distributor and taking into account the provisions of Section 194H, the Tribunal while considering the evidence on record, in our considered opinion, has misdirected itself in considering the case from

VODAFONE CELLULAR LIMITED,COIMBATORE vs. DCIT, COIMBATORE

In the result, all the appeal filed by the assessee are partly allowed for statistical purposes

ITA 377/CHNY/2015[2014-15]Status: DisposedITAT Chennai21 Sept 2017AY 2014-15

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

For Appellant: Shri Salil Kapoor, Advocate
Section 131Section 133ASection 194HSection 201Section 201(1)

transferred to the distributor’. 45. Taking into account the provisions of Section 182 of the Contract Act and the arrangement which has been entered into between the company and the distributor and taking into account the provisions of Section 194H, the Tribunal while considering the evidence on record, in our considered opinion, has misdirected itself in considering the case from

VODAFONE SOUTH LIMITED,CHENNAI vs. ITO TDS, CHENNAI

In the result, all the appeal filed by the assessee are partly allowed for statistical purposes

ITA 1415/CHNY/2014[2010-11]Status: DisposedITAT Chennai21 Sept 2017AY 2010-11

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

For Appellant: Shri Salil Kapoor, Advocate
Section 131Section 133ASection 194HSection 201Section 201(1)

transferred to the distributor’. 45. Taking into account the provisions of Section 182 of the Contract Act and the arrangement which has been entered into between the company and the distributor and taking into account the provisions of Section 194H, the Tribunal while considering the evidence on record, in our considered opinion, has misdirected itself in considering the case from

VODAFONE CELLULAR LIMITED,COIMBATORE vs. DCIT, COIMBATORE

In the result, all the appeal filed by the assessee are partly allowed for statistical purposes

ITA 376/CHNY/2015[2013-14]Status: DisposedITAT Chennai21 Sept 2017AY 2013-14

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

For Appellant: Shri Salil Kapoor, Advocate
Section 131Section 133ASection 194HSection 201Section 201(1)

transferred to the distributor’. 45. Taking into account the provisions of Section 182 of the Contract Act and the arrangement which has been entered into between the company and the distributor and taking into account the provisions of Section 194H, the Tribunal while considering the evidence on record, in our considered opinion, has misdirected itself in considering the case from

VODAFONE SOUTH LIMITED,CHENNAI vs. ITO TDS, CHENNAI

In the result, all the appeal filed by the assessee are partly allowed for statistical purposes

ITA 1414/CHNY/2014[2011-12]Status: DisposedITAT Chennai21 Sept 2017AY 2011-12

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

For Appellant: Shri Salil Kapoor, Advocate
Section 131Section 133ASection 194HSection 201Section 201(1)

transferred to the distributor’. 45. Taking into account the provisions of Section 182 of the Contract Act and the arrangement which has been entered into between the company and the distributor and taking into account the provisions of Section 194H, the Tribunal while considering the evidence on record, in our considered opinion, has misdirected itself in considering the case from

DOOSAN POWER SYSTEMS INDIA PRIVATE LIMITED,HARYANA vs. DCIT CORPORATE CIRCLE 1(1), CHENNAI

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

ITA 1885/CHNY/2017[2013-14]Status: DisposedITAT Chennai23 Jun 2023AY 2013-14

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita Nos.: 1885/Chny/2017 & 665/Chny/2020 िनधा"रण वष" /Assessment Year:2013-14 Doosan Power Systems India The Jcit / Dcit, Pvt. Ltd., V. Corporate Circle -1(1), 16Th Floor, Dlf Square, Chennai. Jacaranda Marg, Near Nh-8, Dlf Phase-Ii, Gurgaon – 122 002. Pan: Aabcb 5946J (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Sandeep Bagmar, Advocate ""यथ" क" ओर से/Respondent By : Shri A. Sasikumar, Cit सुनवाई क" तारीख/Date Of Hearing : 12.06.2023 घोषणा क" तारीख/Date Of Pronouncement : 23.06.2023

For Appellant: Shri Sandeep Bagmar, AdvocateFor Respondent: Shri A. Sasikumar, CIT
Section 143(3)Section 154

transfer pricing assessment proceedings, not appreciating that the financial statements of the Company were available in the public domain. 5. The Ld. AO, Ld. TPO and the Hon'ble DRP erred on facts and in law in violating the provisions of Rule 10B(2) of the Rules by rejecting Harita Techserv Ltd. (‘Harita

DOOSAN POWER SYSTEMS INDIA P.LTD,HARYANA vs. JCIT CORPORATE CIRCLE-1(1), CHENNAI

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

ITA 665/CHNY/2020[2013-14]Status: DisposedITAT Chennai23 Jun 2023AY 2013-14

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita Nos.: 1885/Chny/2017 & 665/Chny/2020 िनधा"रण वष" /Assessment Year:2013-14 Doosan Power Systems India The Jcit / Dcit, Pvt. Ltd., V. Corporate Circle -1(1), 16Th Floor, Dlf Square, Chennai. Jacaranda Marg, Near Nh-8, Dlf Phase-Ii, Gurgaon – 122 002. Pan: Aabcb 5946J (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Sandeep Bagmar, Advocate ""यथ" क" ओर से/Respondent By : Shri A. Sasikumar, Cit सुनवाई क" तारीख/Date Of Hearing : 12.06.2023 घोषणा क" तारीख/Date Of Pronouncement : 23.06.2023

For Appellant: Shri Sandeep Bagmar, AdvocateFor Respondent: Shri A. Sasikumar, CIT
Section 143(3)Section 154

transfer pricing assessment proceedings, not appreciating that the financial statements of the Company were available in the public domain. 5. The Ld. AO, Ld. TPO and the Hon'ble DRP erred on facts and in law in violating the provisions of Rule 10B(2) of the Rules by rejecting Harita Techserv Ltd. (‘Harita

FUJI ELECTRIC INDIA PRIVATE LIMITED,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 1(1), CHENNAI

In the result the appeal of the Assessee is partly allowed for statistical purposes

ITA 701/CHNY/2025[2020-21]Status: DisposedITAT Chennai01 Dec 2025AY 2020-21

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

For Appellant: Shri. Siddhesh Chaugula, C.AFor Respondent: Shri. A R V Sreenivasan, C.I.T
Section 92C

transfer pricing adjustment of Rs.7,96,238/- is allowed. 9. The Assessee has created two provisions in the year end viz., 1) Provision for Installation and Authorised services: Rs.65,50,563/- and 2) Provision for Sales Commission: Rs.1,85,56,926/-. 10. In the Draft Assessment Order, the AO has disallowed the same on the ground that provision

DCIT, CHENNAI vs. V.A. TECH WABAG LIMITED, CHENNAI

Appeal is allowed for statistical purposes

ITA 953/CHNY/2015[2010-11]Status: DisposedITAT Chennai31 Aug 2023AY 2010-11

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Respondent: Dr. S. Palanikumar, CIT
Section 143(3)Section 144C(5)Section 92B

transfer pricing adjustment, the TPO noted from the audit report in Form No.3CEB that there is a claim of revenue expenditure on account of usage of brand name amounting to Rs. 45 Lakhs and payment of Rs. 155 Lakhs for purchase of brand name and capitalize the same in the books of accounts claiming depreciation. The TPO noted the facts

VA TECH WABAG LIMITED,CHENNAI vs. ACIT, CHENNAI

Appeal is allowed for statistical purposes

ITA 807/CHNY/2016[2011-12]Status: DisposedITAT Chennai31 Aug 2023AY 2011-12

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Respondent: Dr. S. Palanikumar, CIT
Section 143(3)Section 144C(5)Section 92B

transfer pricing adjustment, the TPO noted from the audit report in Form No.3CEB that there is a claim of revenue expenditure on account of usage of brand name amounting to Rs. 45 Lakhs and payment of Rs. 155 Lakhs for purchase of brand name and capitalize the same in the books of accounts claiming depreciation. The TPO noted the facts

DCIT, CHENNAI vs. GANAPATHY MEDIA P LTD., CHENNAI

In the result, both, the appeal of the Revenue and cross- objection filed by the assessee are dismissed

ITA 1286/CHNY/2013[2009-10]Status: DisposedITAT Chennai19 Jun 2015AY 2009-10

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony & C.O. No.158/Nds/2013 (In I.T.A. No.1286/Mds/2013) "नधा"रण वष" / Assessment Year : 2009-10

For Appellant: Sh. Sandeep Bagmar. RFor Respondent: Sh. Pathlavath Peerya, CIT
Section 194Section 194CSection 194JSection 40

194C or under Section 194J of the Act. According to the Ld. D.R., the assessee claimed that the term “royalty” does not include consideration paid for sale, distribution or exhibition of cinematographic film. According to the Ld. D.R., the assessee’s further claim was that it was in the business of buying and selling of satellite rights of the feature

DCIT CENTRAL CIRCLE 2, TUTICORIN vs. VVD & SONS (P) LIMITED, TUTICORIN

In the result, both the Cross Objections filed by the assessee are allowed and all the appeals filed by the Revenue are dismissed

ITA 2156/CHNY/2018[2016-17]Status: DisposedITAT Chennai13 Sept 2023AY 2016-17

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.2153, 2154 2155 & 2156/Chny/2018 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2015-16 & 2016-17 & C.O. Nos. 132 & 133/Chny/2018 [In Ita Nos. 2153 & 2154/Chny/2018] The Deputy Commissioner Of Vs. M/S. Vvd & Sons (P) Limited, Income Tax, No. 182, Palayamkottai Road, Central Circle 2, Tuticorin 628 008. Madurai. [Pan:Aaacv8438J] (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) अपीलाथ" की ओर से / Appellant By Shri R. Clement Ramesh Kumar, Cit For : Shri M. Rajan, Cit ""थ" की ओर से/Respondent By Shri R. Vijayaraghavan, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.08.2023 : घोषणा की तारीख /Date Of Pronouncement : 13.09.2023 आदेश /O R D E R Per V. Durga Rao: These Four Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 19, Chennai, Dated 23.04.2018 Relevant To The Assessment Years 2013-14, 2014-15, 2015-16 & 2016-17. 2. The Appeals Filed By The Revenue Are Delayed By Three Days For Which, The Revenue Has Filed Affidavits For Condonation Of Delay, To Which 2

Section 40A(3)

194C of the Act. 9.3 On the other hand, the ld. Counsel for the assessee has strongly supported the order passed by the ld. CIT(A). 9.4 We have heard the rival contentions, perused the materials available on record and gone through the orders of authorities below. In the assessment order, the Assessing Officer made disallowance towards payment made

DCIT CENTRAL CIRCLE 2, TUTICORIN vs. VVD & SONS (P) LIMITED, TUTICORIN

In the result, both the Cross Objections filed by the assessee are allowed and all the appeals filed by the Revenue are dismissed

ITA 2153/CHNY/2018[2013-14]Status: DisposedITAT Chennai13 Sept 2023AY 2013-14

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.2153, 2154 2155 & 2156/Chny/2018 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2015-16 & 2016-17 & C.O. Nos. 132 & 133/Chny/2018 [In Ita Nos. 2153 & 2154/Chny/2018] The Deputy Commissioner Of Vs. M/S. Vvd & Sons (P) Limited, Income Tax, No. 182, Palayamkottai Road, Central Circle 2, Tuticorin 628 008. Madurai. [Pan:Aaacv8438J] (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) अपीलाथ" की ओर से / Appellant By Shri R. Clement Ramesh Kumar, Cit For : Shri M. Rajan, Cit ""थ" की ओर से/Respondent By Shri R. Vijayaraghavan, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.08.2023 : घोषणा की तारीख /Date Of Pronouncement : 13.09.2023 आदेश /O R D E R Per V. Durga Rao: These Four Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 19, Chennai, Dated 23.04.2018 Relevant To The Assessment Years 2013-14, 2014-15, 2015-16 & 2016-17. 2. The Appeals Filed By The Revenue Are Delayed By Three Days For Which, The Revenue Has Filed Affidavits For Condonation Of Delay, To Which 2

Section 40A(3)

194C of the Act. 9.3 On the other hand, the ld. Counsel for the assessee has strongly supported the order passed by the ld. CIT(A). 9.4 We have heard the rival contentions, perused the materials available on record and gone through the orders of authorities below. In the assessment order, the Assessing Officer made disallowance towards payment made

DCIT CENTRAL CIRCLE 2, TUTICORIN vs. VVD & SONS (P) LIMITED, TUTICORIN

In the result, both the Cross Objections filed by the assessee are allowed and all the appeals filed by the Revenue are dismissed

ITA 2155/CHNY/2018[2015-16]Status: DisposedITAT Chennai13 Sept 2023AY 2015-16

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.2153, 2154 2155 & 2156/Chny/2018 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2015-16 & 2016-17 & C.O. Nos. 132 & 133/Chny/2018 [In Ita Nos. 2153 & 2154/Chny/2018] The Deputy Commissioner Of Vs. M/S. Vvd & Sons (P) Limited, Income Tax, No. 182, Palayamkottai Road, Central Circle 2, Tuticorin 628 008. Madurai. [Pan:Aaacv8438J] (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) अपीलाथ" की ओर से / Appellant By Shri R. Clement Ramesh Kumar, Cit For : Shri M. Rajan, Cit ""थ" की ओर से/Respondent By Shri R. Vijayaraghavan, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.08.2023 : घोषणा की तारीख /Date Of Pronouncement : 13.09.2023 आदेश /O R D E R Per V. Durga Rao: These Four Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 19, Chennai, Dated 23.04.2018 Relevant To The Assessment Years 2013-14, 2014-15, 2015-16 & 2016-17. 2. The Appeals Filed By The Revenue Are Delayed By Three Days For Which, The Revenue Has Filed Affidavits For Condonation Of Delay, To Which 2

Section 40A(3)

194C of the Act. 9.3 On the other hand, the ld. Counsel for the assessee has strongly supported the order passed by the ld. CIT(A). 9.4 We have heard the rival contentions, perused the materials available on record and gone through the orders of authorities below. In the assessment order, the Assessing Officer made disallowance towards payment made