K.P.R.MILL LIMITED ,CHENNAI vs. ACIT CORPORATE CIRCLE 2 , COIMBATORE

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

Bench: Shri N.R.S. Ganesan & Shri S. Jayaramanआयकर अपील सं./Ita No.1915/Mds/2017 "नधा"रण वष" / Assessment Year : 2013-14

section pre-supposes that there is another value attached to the said goods which would represent the market value of the goods. I find that there is nothing brought on record to show as to how the price recorded in the Books does not correspond to the market value of goods, when sold in the open market, especially

YCH LOGISTICS (INDIA) PRIVATE LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

transfer pricing adjustment for fresh adjudication. Simultaneously, the assessee also challenged the order of Tribunal i.e., original order passed in ITA No.322/Mds/2016 dated 30.06.2016 and also challenged the Tribunal order passed in M.P. No.218/Mds/2016 dated 04.04.2017 before Hon’ble High Court of Madras and the Hon’ble High Court in Tax Case Appeal Nos.480 and 473 of 2017 vide order

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

price of the flats in the project at Rs.27,000/-, however, on verification it is found to be Rs.26,414/- ). To that extent, the sales disclosed were understated. Further, the appellant has paid an extra consideration of Rs.3,56,06,250/- to its holding company EID Parry on account of land cost u/s.40A(2)(b). Based on work order

DCIT, CHENNAI vs. M/S. AVT MC CORMICK INGREDIENTS LTD., CHENNAI

In the result, the appeals of the Revenue in ITA No

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

Transfer Pricing Officer and TPO-I, Chennai in order dated 09.01.2014 in F.No.104/TPO-I/A.Y.2010-11 held that international transactions of the assessee company are within Arm’s Length Price and hence no adjustment is considered necessary for the assessment year 2010-2011 and the assessment order was passed u/s.143(3)r.w.s. 92CA(3) of the Act dated 17.03.2014. The sole dispute

AVT MC CORMICK INGREDIENTS PVT LTD.,CHENNAI vs. ADDL. CIT, CHENNAI

In the result, the appeals of the Revenue in ITA No

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

Transfer Pricing Officer and TPO-I, Chennai in order dated 09.01.2014 in F.No.104/TPO-I/A.Y.2010-11 held that international transactions of the assessee company are within Arm’s Length Price and hence no adjustment is considered necessary for the assessment year 2010-2011 and the assessment order was passed u/s.143(3)r.w.s. 92CA(3) of the Act dated 17.03.2014. The sole dispute

DCIT, CHENNAI vs. M/S. AVT MC CORMICK INGREDIENTS LTD., CHENNAI

In the result, the appeals of the Revenue in ITA No

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

Transfer Pricing Officer and TPO-I, Chennai in order dated 09.01.2014 in F.No.104/TPO-I/A.Y.2010-11 held that international transactions of the assessee company are within Arm’s Length Price and hence no adjustment is considered necessary for the assessment year 2010-2011 and the assessment order was passed u/s.143(3)r.w.s. 92CA(3) of the Act dated 17.03.2014. The sole dispute

DCIT, CHENNAI vs. M/S. AVT MC CORMICK INGREDIENTS LTD., CHENNAI

In the result, the appeals of the Revenue in ITA No

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

Transfer Pricing Officer and TPO-I, Chennai in order dated 09.01.2014 in F.No.104/TPO-I/A.Y.2010-11 held that international transactions of the assessee company are within Arm’s Length Price and hence no adjustment is considered necessary for the assessment year 2010-2011 and the assessment order was passed u/s.143(3)r.w.s. 92CA(3) of the Act dated 17.03.2014. The sole dispute

SIVANANDHA MILLS LIMITED,COIMBATORE vs. ACIT, COIMBATORE

In the result, ITA No.2106/Mds/13 is partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

price, which was much higher than the guideline value, which would normally have ended as a distress sale, under such circumstances, with much lesser consideration, the sale extracted much higher value which was incredible, considering overall circumstances under which such sale took place. The Assessee had paid these persons for such services, by way of commission, which totaled to about

M/S. SIVANANDHA MILLS LTD.,COIMBATORE vs. DCIT, COIMBATORE

In the result, ITA No.2106/Mds/13 is partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

price, which was much higher than the guideline value, which would normally have ended as a distress sale, under such circumstances, with much lesser consideration, the sale extracted much higher value which was incredible, considering overall circumstances under which such sale took place. The Assessee had paid these persons for such services, by way of commission, which totaled to about

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

Bench: Shri Mahavir Singhand Shri G. Manjunatha

price the same would not conclusively establish the correctness of the claim made by an assessee if the AO is of the opinion that the transaction is by way of subterfuge or device in order to avoid tax which the assessee is otherwise liable to pay or that the transaction is illusory or colourable or that the assessee has acted

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

Bench: Shri Mahavir Singhand Shri G. Manjunatha

price the same would not conclusively establish the correctness of the claim made by an assessee if the AO is of the opinion that the transaction is by way of subterfuge or device in order to avoid tax which the assessee is otherwise liable to pay or that the transaction is illusory or colourable or that the assessee has acted

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

Bench: Shri Mahavir Singhand Shri G. Manjunatha

price the same would not conclusively establish the correctness of the claim made by an assessee if the AO is of the opinion that the transaction is by way of subterfuge or device in order to avoid tax which the assessee is otherwise liable to pay or that the transaction is illusory or colourable or that the assessee has acted

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

Bench: Shri Mahavir Singhand Shri G. Manjunatha

price the same would not conclusively establish the correctness of the claim made by an assessee if the AO is of the opinion that the transaction is by way of subterfuge or device in order to avoid tax which the assessee is otherwise liable to pay or that the transaction is illusory or colourable or that the assessee has acted

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

Bench: Shri Mahavir Singhand Shri G. Manjunatha

price the same would not conclusively establish the correctness of the claim made by an assessee if the AO is of the opinion that the transaction is by way of subterfuge or device in order to avoid tax which the assessee is otherwise liable to pay or that the transaction is illusory or colourable or that the assessee has acted

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

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

Bench: Shri Mahavir Singhand Shri G. Manjunatha

price the same would not conclusively establish the correctness of the claim made by an assessee if the AO is of the opinion that the transaction is by way of subterfuge or device in order to avoid tax which the assessee is otherwise liable to pay or that the transaction is illusory or colourable or that the assessee has acted

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

Bench: Shri Mahavir Singhand Shri G. Manjunatha

price the same would not conclusively establish the correctness of the claim made by an assessee if the AO is of the opinion that the transaction is by way of subterfuge or device in order to avoid tax which the assessee is otherwise liable to pay or that the transaction is illusory or colourable or that the assessee has acted

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

Bench: Shri Mahavir Singhand Shri G. Manjunatha

price the same would not conclusively establish the correctness of the claim made by an assessee if the AO is of the opinion that the transaction is by way of subterfuge or device in order to avoid tax which the assessee is otherwise liable to pay or that the transaction is illusory or colourable or that the assessee has acted

DCIT, CORPORATE CIRCLE - 1(1),, CHENNAI vs. M/S. ALLIANCE GRANIMARMO PVT. LTD.,, CHENNAI

price variation. We also note that the Ld. First appellate authority in his order supra, extracted herein above has analyzed the issue in great detail, inter-alia, by considering the remand report of the AO 26.02.2019. The Ld. Counsel for the assesse has, through his copies of invoices and shipping bills placed in the paper book, vividly explained that there

ASSISTANT COMMISSIONER OF INCOME-TAX, MADURAI vs. ALBA INDUSTRIES LIMITED, CHENNAI

Bench: Shri Aby T. Varkey & Shri Jagadish

transfer of funds through bank from the group entity and incurring of expenditure by the through bank from the group entity and incurring of expenditure by the through bank from the group entity and incurring of expenditure by the Appellant from such funds by withdrawing the same from the bank. Appellant from such funds by withdrawing the same from