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20 results for “transfer pricing”+ Section 54Fclear

Sorted by relevance

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Key Topics

Section 26320Section 143(3)20Section 54F14Section 14713Capital Gains9Section 28Deduction8Addition to Income8Reassessment7Section 148

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

transfer' under Section 2(47) of the Act to 'purchase` and the same\ncannot be applied to Section 54F.\n6.\nThe CIT (Appeals) and AO failed to take note of CIT vs. Aravinda\nReddy (120 ITR 46 SC) wherein it was held that the word 'purchase' in\nSection 54F(1) of the Act must be given it common meaning

GOKULAKRISHNA,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX, NON CORPORATE CIRCLE 8(1), CHENNAI

6
Long Term Capital Gains6
Section 104

In the result, the appeal filed by the assessee is allowed and the stay\napplication is dismissed

ITA 1088/CHNY/2025[2017-18]Status: DisposedITAT Chennai17 Jun 2025AY 2017-18
Section 147Section 250

price. He argued that there is no element of transfer so as to attract\nthe provision of section 2(47) of the Act and hence there cannot be any\nlevy of tax on capital gain under section 45 of the Act on the event of\nintroduction of a new partner. He has further submitted that even if the\namount

ANTHIAH PANCRAS,TIRUVANNAMALAI vs. ITO WARD 1, THIRUVANNAMALAI

In the result, the appeal filed by the assessee for ay: 2008-09 shall

ITA 27/CHNY/2017[2008-09]Status: DisposedITAT Chennai21 Oct 2019AY 2008-09

Bench: Shri N.R.S. Ganesan & Shri Ramit Kochar

Section 10Section 143(3)Section 148Section 2

price was around ` 3 ITA Nos.27 & 28/Chny/2017 :- 30 -: lacs per acre at that point of time of the land in that area as there was increased market activities in the year 2008 and not ` 1 lacs per acre as is recorded in the sale deed dated 11.09.2008. The learned VAO has also stated that this land however could not fetch

ANTHIAH PANCRAS,TIRUVANNAMALAI vs. ITO WARD 1, THIRUVANNAMALAI

In the result, the appeal filed by the assessee for ay: 2008-09 shall

ITA 28/CHNY/2017[2009-10]Status: DisposedITAT Chennai21 Oct 2019AY 2009-10

Bench: Shri N.R.S. Ganesan & Shri Ramit Kochar

Section 10Section 143(3)Section 148Section 2

price was around ` 3 ITA Nos.27 & 28/Chny/2017 :- 30 -: lacs per acre at that point of time of the land in that area as there was increased market activities in the year 2008 and not ` 1 lacs per acre as is recorded in the sale deed dated 11.09.2008. The learned VAO has also stated that this land however could not fetch

VANAVIL ESTATE,CHENNAI vs. PCIT(CENTRAL), CHENNAI

In the result, the appeal for both AYs 2017

ITA 925/CHNY/2024[2017-18]Status: DisposedITAT Chennai12 Feb 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadishआयकरअपीलसं./Ita Nos.925 & 926/Chny/2024 िनधा"रणवष"/Assessment Years: 2017-18 & 2018-19 V. Vanavil Estate, The Pcit (Central), 4/20, Duraiswamy Reddy Street, Chennai-1. West Tambaram, Chennai-600 045. [Pan: Aalfv 0770 H] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri S. Sridhar, AdvocateFor Respondent: Shri R. Clement Ramesh-
Section 133ASection 148Section 263

54F of the Act and assigned certain reasons for that. Therefore, the larger issue was pending before certain reasons for that. Therefore, the larger issue was pending before certain reasons for that. Therefore, the larger issue was pending before the Commissioner of Appeals, and in such circumstances, the the Commissioner of Appeals, and in such circumstances, the the Commissioner

VANAVIL ESTATE,CHENNAI vs. PCIT CENTRAL, CHENNAI

In the result, the appeal for both AYs 2017

ITA 926/CHNY/2024[2018-19]Status: DisposedITAT Chennai12 Feb 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri Jagadishआयकरअपीलसं./Ita Nos.925 & 926/Chny/2024 िनधा"रणवष"/Assessment Years: 2017-18 & 2018-19 V. Vanavil Estate, The Pcit (Central), 4/20, Duraiswamy Reddy Street, Chennai-1. West Tambaram, Chennai-600 045. [Pan: Aalfv 0770 H] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri S. Sridhar, AdvocateFor Respondent: Shri R. Clement Ramesh-
Section 133ASection 148Section 263

54F of the Act and assigned certain reasons for that. Therefore, the larger issue was pending before certain reasons for that. Therefore, the larger issue was pending before certain reasons for that. Therefore, the larger issue was pending before the Commissioner of Appeals, and in such circumstances, the the Commissioner of Appeals, and in such circumstances, the the Commissioner

SHRI RAMASWAMY SHIVARAMAN,,CHENNAI vs. ACIT, CC - 1 (1),, CHENNAI

ITA 571/CHNY/2020[2016-17]Status: DisposedITAT Chennai17 Dec 2021AY 2016-17

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकरअपीलसं./Ita No.571/Chny/2020 िनधा"रणवष"/Assessment Year: 2016-17

Section 54F

price of M/s.CL Educate Ltd., when it was allotted to the assessee on 07.09.2015 and subsequent transfer of shares to his mother at a much lesser rate of Rs.179.15 per share, and opined that transaction of purchase of property by transfer of equity shares is nothing but an arranged transaction between two related parties and hence, cannot be considered

DCIT, NCC - 2 (1),, CHENNAI vs. SHRI KEEZHAYUR SOWRIRAJAN SREENIVASAN,, CHENNAI

In the result, appeal filed by the Revenue is dismissed

ITA 2369/CHNY/2019[2016-17]Status: DisposedITAT Chennai15 Jun 2022AY 2016-17

Bench: Shri G. Manjunatha & Shri Anikesh Banerjee

For Appellant: Mr. K.Senguttuvan, Advocate &
Section 54F

price agreed on 2006, without considering the inflation in the real estate market that had happened in these years. The question arises is that will anyone sell their right at a lower rate especially in a immovable property, when the market rates have grown manifold. Further, it can be mentioned here that the assessee has not even explored the possibility

MOSBACHER INDIA LLC,CHENNAI vs. ADDL. DIT, CHENNAI

In the result, the appeal is partly allowed in the terms indicated above

ITA 1085/CHNY/2015[2010-11]Status: DisposedITAT Chennai29 Nov 2016AY 2010-11
Section 143(3)Section 42(2)Section 42(2)(b)

Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any foreign company. [12] In order to successfully invoke the provisions of Section 144C, thus, two basic conditions are required to be fulfilled: - the assessee is an eligible assessee [i.e. (i) any person in whose case the variation referred to the income or loss in the returned income

LALITHA KUMARI PRAKASH CHAND,CHENNAI vs. ACIT NON CORP. WARD 10(1), CHENNAI

In the result, appeal filed by the assessee is treated as

ITA 841/CHNY/2019[2015-16]Status: DisposedITAT Chennai20 Jul 2022AY 2015-16

Bench: Shri V. Durga Rao & Shri G. Manjunatha

For Appellant: Mr. Guru Bashyam, CITFor Respondent: 19.05.2022
Section 143(3)Section 50CSection 56(2)(vii)

price and market value of flats. It was explanation of the assessee that the Assessing Officer has made addition without affording reasonable opportunity of hearing being heard to the assessee Further, before invoking provisions of section 56(2)(vii)(b)(ii) of the Act, the Assessing Officer should have referred valuation to the valuation cell. 20 Therefore, pleaded that

ACIT, CHENNAI vs. TEJENDRA KUMAR GOLECHA, CHENNAI

In the result, the Revenue’s appeal is partly allowed

ITA 505/CHNY/2013[2007-08]Status: DisposedITAT Chennai31 Oct 2017AY 2007-08

Bench: Shri Sanjay Arora & Shri Duvvuru Rl Reddy

For Appellant: Shri S.Sridhar, AdvocateFor Respondent: 02.08.2017
Section 143(3)Section 54FSection 68

Price as on 31-03-97 Rs. 9,80,000/- (F.Y. 1996-97) ------------------ Long Term Capital Gain Rs. 25,39,800/- ------------------ Sale Consideration Rs. 35,19,800/- Less Indexed cost of acquisition 980000 x 519 (F.Y. 06-07) 305 (F.Y. 96-97) Rs. 16,67,606/- ------------------ Long Term Capital Gain Rs. 18,52,194/- ------------------ Capital Gain on Sale of Land

ACIT NON CORP. CIRCLE 1 , COIMBATORE vs. P.SUBRAMANIAN , COIMBATORE

In the result, the appeal filed by the Revenue stands dismissed

ITA 1670/CHNY/2017[2013-14]Status: DisposedITAT Chennai28 Feb 2018AY 2013-14

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No.1670/Chny/2017 "नधा"रण वष" / Assessment Year : 2013-14

For Appellant: Shri Vijay Kumar PunnaFor Respondent: Shri A. Arjunaraj, CA
Section 28Section 54ESection 54F

54F of the Act. The assessee further claimed deduction under Section 54EC of the Act to the extent of ₹50,00,000/-. According to the Ld. Jr. Standing Counsel, the Assessing Officer found that the share purchase agreement 3 I.T.A. No.1670/Chny/17 discloses the sale of shares at ₹81/- per share to M/s Tube Investments of India Limited. There

ASHA MARTHANDA PILLAI,CHENNAI vs. ITO, CHENNAI

In the result, appeal of the assessee is partly allowed

ITA 3435/CHNY/2016[2013-14]Status: DisposedITAT Chennai27 Apr 2017AY 2013-14

Bench: Shri Abraham P. George]

For Appellant: Shri. M. Murali Mohan, JCIT
Section 54Section 54(1)Section 54F

54F of the Act, assessee had to purchase within a period of one year or before two years after the date on which transfer took place, a residential house or assessee had to construct a residential house within a period of three years after the date of sale. Here, in our opinion, the intention of the assessee was to purchase

SRI K.SRIKANTH,,CHENNAI vs. ACIT,, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

ITA 1015/CHNY/2012[2001-02]Status: DisposedITAT Chennai19 May 2020AY 2001-02

Bench: Shri George Mathan & Shri Ramit Kochar

For Appellant: Mr. S.Sridhar, AdvFor Respondent: Dr. M.Srinivasa Rao, CIT
Section 143(3)Section 147Section 263

price of each share of Rs. 320 instead of Rs. 400 per share( Rs. 15 crores/375000 shares), which led to invocation of revisionary powers u/s 263 by learned CIT. The second issue on which learned CIT invoked revisionary powers u/s 263 was with respect to the deduction ITA No.307/Chny/2010 & ITA Nos.1015 & 1016/Chny/2012 & :- 25 -: allowed by AO u/s 54F

SHRI K.SRIKANTH,CHENNAI vs. ACIT, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

ITA 307/CHNY/2010[2001-02]Status: DisposedITAT Chennai19 May 2020AY 2001-02

Bench: Shri George Mathan & Shri Ramit Kochar

For Appellant: Mr. S.Sridhar, AdvFor Respondent: Dr. M.Srinivasa Rao, CIT
Section 143(3)Section 147Section 263

price of each share of Rs. 320 instead of Rs. 400 per share( Rs. 15 crores/375000 shares), which led to invocation of revisionary powers u/s 263 by learned CIT. The second issue on which learned CIT invoked revisionary powers u/s 263 was with respect to the deduction ITA No.307/Chny/2010 & ITA Nos.1015 & 1016/Chny/2012 & :- 25 -: allowed by AO u/s 54F

SRI K.SRIKANTH,,CHENNAI vs. ACIT,, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

ITA 1016/CHNY/2012[2001-02]Status: DisposedITAT Chennai19 May 2020AY 2001-02

Bench: Shri George Mathan & Shri Ramit Kochar

For Appellant: Mr. S.Sridhar, AdvFor Respondent: Dr. M.Srinivasa Rao, CIT
Section 143(3)Section 147Section 263

price of each share of Rs. 320 instead of Rs. 400 per share( Rs. 15 crores/375000 shares), which led to invocation of revisionary powers u/s 263 by learned CIT. The second issue on which learned CIT invoked revisionary powers u/s 263 was with respect to the deduction ITA No.307/Chny/2010 & ITA Nos.1015 & 1016/Chny/2012 & :- 25 -: allowed by AO u/s 54F

ACIT,, CHENNAI vs. SRI. K.SRIKANTH,, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

ITA 1324/CHNY/2012[2001-02]Status: DisposedITAT Chennai19 May 2020AY 2001-02

Bench: Shri George Mathan & Shri Ramit Kochar

For Appellant: Mr. S.Sridhar, AdvFor Respondent: Dr. M.Srinivasa Rao, CIT
Section 143(3)Section 147Section 263

price of each share of Rs. 320 instead of Rs. 400 per share( Rs. 15 crores/375000 shares), which led to invocation of revisionary powers u/s 263 by learned CIT. The second issue on which learned CIT invoked revisionary powers u/s 263 was with respect to the deduction ITA No.307/Chny/2010 & ITA Nos.1015 & 1016/Chny/2012 & :- 25 -: allowed by AO u/s 54F

WINVEST HOLDINGS (I) PVT. LTD.,CHENNAI vs. ACIT CORPORATE CIRCLE 3(2), CHENNAI

In the result, the appeal filed by the assessee stands

ITA 1519/CHNY/2019[2014-15]Status: DisposedITAT Chennai23 Aug 2019AY 2014-15

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. No.1519/Chny/2019. "नधा"रण वष" /Assessment Year : 2014-2015. M/S. Winvest Holdings (I) Pvt. Ltd, Vs The Assistant Commissioner Of D-16, 2Nd Floor, Nelson Chambers, Income Tax, No.115 Nelson Manickam Road, Corporate Circle 3(2), Aminjikarai, Chennai. Chennai 600 029. [Pan Aaacw 7724Q] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Dr. P. Daniel, Advocate
Section 142(1)Section 143(3)Section 263

price and commercial terms; Identification and appointment of merchant banker (s) and other advisors and coordinating with them: Prepare planning document, budgeting financials, cash report and cash flow projections, detailed report on financial operating and business plans; Undertake market research, market studies, long—term and short – term strategic plans and valuation analysis. Provide a detailed report on the process involved

SMT. RENU AGARWAL,,CHENNAI vs. ITO, NCW - 10(5),, CHENNAI

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

ITA 271/CHNY/2020[2014-15]Status: DisposedITAT Chennai27 Jul 2021AY 2014-15

Bench: Shri V. Durga Rao & Shri S. Jayaraman

For Appellant: Mr. J. Prabhakar, C.A %&For Respondent: Mr. G. Srinivasa Rao, CIT
Section 263

section 263 dated 22/3/2019, by admitting the appeal on record and disposing the case on merits of the issues involved.” I.T.A No.271/Chny/2020 :- 3 -: 3. From the above, it is clear that there is a delay in filing of the appeal on the basis of wrong advice given by the Chartered Accountant. In our opinion, in the affidavit the assessee

SASIKALA RAGHUPATHY,CHENNAI vs. ACIT CENTRAL CIRCLE 3(1), CHENNAI

In the result appeal of the assessee is allowed

ITA 366/CHNY/2018[2008-09]Status: DisposedITAT Chennai16 Oct 2018AY 2008-09

Bench: Shri A.Mohan Alankamony & Shri Duvvuru Rl Reddyआयकर अपील सं./I.T.A.No.366/Chny/2018 ("नधा"रण वष" / Assessment Year: 2008-09) Vs The Acit, Smt. Sasikala Raghupathy, New No.60, Old No.100, Central Circle 3(1), Iv Street, Abhiramapuram, Chennai. Chennai – 600 018. Pan: Aaafr5481B (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri Ca Jharna B. Harilal, Fca ""यथ" क" ओर से/Respondent By : Shri S. Bharath, Cit

For Appellant: Shri CA Jharna B. Harilal, FCAFor Respondent: Shri S. Bharath, CIT
Section 132Section 143(3)Section 153ASection 153CSection 250(6)Section 263Section 54F

transfer of expenses where without application of mind and without conducting necessary enquiries. (v) Subsequently consequent to search action initiated U/s.132 of the Act, CIT(A) dropped the proceedings U/s.263 of the Act on 18.02.2014 on the ground that the proceedings U/s.153A of the Act has overtaken the proceedings U/s.263 of the Act. (vi) Thereafter the Ld.AO passed order U/s.143