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14 results for “reassessment u/s 147”+ Section 40Aclear

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Key Topics

Exemption13Addition to Income13Section 40A(3)4

M/S THE REGIONAL AGRO INDUSTRIAL DEVELOPMENT COOPERATIVE OF KERALA LTD,KANNUR vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1, KANNUR RANGE

ITA 563/COCH/2025[2010-11]Status: DisposedITAT Cochin18 Nov 2025AY 2010-11

Bench: The Tribunal Within The Time Prescribed. Accordingly, The Delay Of 69 Days In Filing The Present Appeal Is Condoned.

For Appellant: Shri Suresh KumarFor Respondent: Smt. Leena Lal
Section 143(3)Section 147Section 148Section 250Section 40A(3)

147 of the Income Tax Act, 1961 for the Assessment Year 2010-2011. 1.1. There is a delay of 69 days in filing the present appeal. In the application seeking condonation of delay it has been explained that the Accountants Manager who had been responsible for handling Assessment Year 2010-2011 income tax matters was on Medical Leave prior

M/S. VIJAYALAXMICASHEW CO.,,KOLLAM vs. THE ACIT, KOLLAM

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

ITA 48/COCH/2016[2010-11]Status: DisposedITAT Cochin03 Feb 2020AY 2010-11

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

Section 40A(2). Hence, there was no shifting of profits in favour of sister concerns for their benefit as the transfer price was based on ultimate export price obtaining for respective grade(s) which therefore, constituted ALP on the date of relevant export contract. I.T.A. Nos.37 to 49/Coch/2016 8.7 It cannot stand to reason that the sale price of cashew

SMT. T.C. USHA,KOLLAM vs. THE ACIT, KOLLAM

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

ITA 44/COCH/2016[2009-10]Status: DisposedITAT Cochin03 Feb 2020AY 2009-10

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

Section 40A(2). Hence, there was no shifting of profits in favour of sister concerns for their benefit as the transfer price was based on ultimate export price obtaining for respective grade(s) which therefore, constituted ALP on the date of relevant export contract. I.T.A. Nos.37 to 49/Coch/2016 8.7 It cannot stand to reason that the sale price of cashew

M/S. VIJAYALAXMICASHEW CO.,,KOLLAM vs. THE ACIT, KOLLAM

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

ITA 49/COCH/2016[2011-12]Status: DisposedITAT Cochin03 Feb 2020AY 2011-12

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

Section 40A(2). Hence, there was no shifting of profits in favour of sister concerns for their benefit as the transfer price was based on ultimate export price obtaining for respective grade(s) which therefore, constituted ALP on the date of relevant export contract. I.T.A. Nos.37 to 49/Coch/2016 8.7 It cannot stand to reason that the sale price of cashew

SRI.R.PRAKASH,KOLLAM vs. THE ACIT, KOLLAM

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

ITA 40/COCH/2016[2010-11]Status: DisposedITAT Cochin03 Feb 2020AY 2010-11

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

Section 40A(2). Hence, there was no shifting of profits in favour of sister concerns for their benefit as the transfer price was based on ultimate export price obtaining for respective grade(s) which therefore, constituted ALP on the date of relevant export contract. I.T.A. Nos.37 to 49/Coch/2016 8.7 It cannot stand to reason that the sale price of cashew

SRI.K.RAVINDRANATHAN NAIR,KOLLAM vs. THE ACIT, KOLLAM

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

ITA 46/COCH/2016[2008-09]Status: DisposedITAT Cochin03 Feb 2020AY 2008-09

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

Section 40A(2). Hence, there was no shifting of profits in favour of sister concerns for their benefit as the transfer price was based on ultimate export price obtaining for respective grade(s) which therefore, constituted ALP on the date of relevant export contract. I.T.A. Nos.37 to 49/Coch/2016 8.7 It cannot stand to reason that the sale price of cashew

SRI.R. PRATAP,KOLLAM vs. THE ACIT, KOLLAM

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

ITA 39/COCH/2016[2010-11]Status: DisposedITAT Cochin03 Feb 2020AY 2010-11

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

Section 40A(2). Hence, there was no shifting of profits in favour of sister concerns for their benefit as the transfer price was based on ultimate export price obtaining for respective grade(s) which therefore, constituted ALP on the date of relevant export contract. I.T.A. Nos.37 to 49/Coch/2016 8.7 It cannot stand to reason that the sale price of cashew

SRI.R.PRAKASH,KOLLAM vs. THE ACIT, KOLLAM

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

ITA 42/COCH/2016[2010-11]Status: DisposedITAT Cochin03 Feb 2020AY 2010-11

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

Section 40A(2). Hence, there was no shifting of profits in favour of sister concerns for their benefit as the transfer price was based on ultimate export price obtaining for respective grade(s) which therefore, constituted ALP on the date of relevant export contract. I.T.A. Nos.37 to 49/Coch/2016 8.7 It cannot stand to reason that the sale price of cashew

SRI.R. PRATAP,KOLLAM vs. THE ACIT, KOLLAM

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

ITA 37/COCH/2016[2009-10]Status: DisposedITAT Cochin03 Feb 2020AY 2009-10

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

Section 40A(2). Hence, there was no shifting of profits in favour of sister concerns for their benefit as the transfer price was based on ultimate export price obtaining for respective grade(s) which therefore, constituted ALP on the date of relevant export contract. I.T.A. Nos.37 to 49/Coch/2016 8.7 It cannot stand to reason that the sale price of cashew

SRI.R.PRAKASH,KOLLAM vs. THE ACIT, KOLLAM

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

ITA 43/COCH/2016[2011-12]Status: DisposedITAT Cochin03 Feb 2020AY 2011-12

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

Section 40A(2). Hence, there was no shifting of profits in favour of sister concerns for their benefit as the transfer price was based on ultimate export price obtaining for respective grade(s) which therefore, constituted ALP on the date of relevant export contract. I.T.A. Nos.37 to 49/Coch/2016 8.7 It cannot stand to reason that the sale price of cashew

SMT. T.C. USHA,KOLLAM vs. THE ACIT, KOLLAM

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

ITA 45/COCH/2016[2010-11]Status: DisposedITAT Cochin03 Feb 2020AY 2010-11

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

Section 40A(2). Hence, there was no shifting of profits in favour of sister concerns for their benefit as the transfer price was based on ultimate export price obtaining for respective grade(s) which therefore, constituted ALP on the date of relevant export contract. I.T.A. Nos.37 to 49/Coch/2016 8.7 It cannot stand to reason that the sale price of cashew

SRI.R. PRATAP,KOLLAM vs. THE ACIT, KOLLAM

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

ITA 38/COCH/2016[2010-11]Status: DisposedITAT Cochin03 Feb 2020AY 2010-11

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

Section 40A(2). Hence, there was no shifting of profits in favour of sister concerns for their benefit as the transfer price was based on ultimate export price obtaining for respective grade(s) which therefore, constituted ALP on the date of relevant export contract. I.T.A. Nos.37 to 49/Coch/2016 8.7 It cannot stand to reason that the sale price of cashew

M/S. VIJAYALAXMICASHEW CO.,,KOLLAM vs. THE ACIT, KOLLAM

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

ITA 47/COCH/2016[2008-09]Status: DisposedITAT Cochin03 Feb 2020AY 2008-09

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

Section 40A(2). Hence, there was no shifting of profits in favour of sister concerns for their benefit as the transfer price was based on ultimate export price obtaining for respective grade(s) which therefore, constituted ALP on the date of relevant export contract. I.T.A. Nos.37 to 49/Coch/2016 8.7 It cannot stand to reason that the sale price of cashew

SRI.R.PRAKASH,KOLLAM vs. THE ACIT, KOLLAM

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

ITA 41/COCH/2016[2009-10]Status: DisposedITAT Cochin03 Feb 2020AY 2009-10

Bench: S/Shri Chandra Poojari, Am&George George K., Jm

Section 40A(2). Hence, there was no shifting of profits in favour of sister concerns for their benefit as the transfer price was based on ultimate export price obtaining for respective grade(s) which therefore, constituted ALP on the date of relevant export contract. I.T.A. Nos.37 to 49/Coch/2016 8.7 It cannot stand to reason that the sale price of cashew