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4 results for “transfer pricing”+ Section 144Bclear

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Key Topics

Section 80G12Section 143(3)8Section 92C7Transfer Pricing4Section 144C3Section 353Addition to Income3Comparables/TP2Deduction2

APPLEXUS TECHNOLOGIES PRIVATE LIMITED,TRIVANDRUM vs. DCIT, KOTTAYAM

ITA 955/COCH/2024[2021-2022]Status: DisposedITAT Cochin13 Nov 2025AY 2021-2022
For Appellant: Shri Reuben JosephFor Respondent: Shri Sanjit Kumar Das
Section 143(3)Section 144BSection 144CSection 144C(1)Section 144C(5)

144B of the Income Tax Act, 1961 [hereinafter referred to as ‘the Act’], as per the directions issued by Dispute Resolution Panel - 2, Bengaluru [for short ‘DRP’], on 12/08/2024 under Section 144C(5) of the Act for the Assessment Year 2021-2022. 2. The Assessee has raised multiple grounds of appeal which can be grouped as under: Ground No.1: Incorrect

UST GLOBAL TECHNOLOGY SERVICES (INDIA) PRIVATE LIMITED,KOCHI vs. DCIT,CORPORATE CIRCLE 2(1), KOCHI

Disallowance2

In the result, appeal filed by the assessee stands partly allowed\nfor statistical purpose and the stay application is dismissed as\ninfructuous

ITA 1071/COCH/2024[2021-22]Status: DisposedITAT Cochin08 Sept 2025AY 2021-22
For Respondent: \nShri Rajakannam, Advocate
Section 143Section 92C

Transfer Pricing Officer (TPO) regarding IT services and interest on delayed receivables.", "held": "The Tribunal found merit in the appellant's submission that the TPO ought to have applied an upper turnover limit filter for selecting comparables, in addition to the lower limit. The existing benchmarking exercise by the TPO was considered flawed.", "result": "Partly Allowed", "sections": ["Section

APOLLO TYRES LTD.,COCHIN vs. DCIT CORPORATE CIR 1(1), KOCHI

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

ITA 679/COCH/2024[2020-21]Status: DisposedITAT Cochin10 Sept 2025AY 2020-21

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm Assessment Year: 2020-21 Apollo Tyres Ltd. .......... Appellant 3Rd Floor, Areekal Mansion, Panampilly Nagar, Kochi 682036 [Pan: Aaaca6990Q] Vs. Acit, Corporate Circle-1(1), Kochi ......... Respondent Assessee By: Shri Abraham Joseph Markos, Adv. Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 20.08.2025 Date Of Pronouncement: 10.09.2025

For Appellant: Shri Abraham Joseph Markos, AdvFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 115JSection 143(3)Section 154Section 35Section 92C

144B of the Income-tax Act, 1961 ('the Act') dated 20th June, 2024, by the Assessment Unit, Income Tax Department (AO') pursuant to the directions of the Dispute Resolution Panel ('DRP'), and the additions/disallowances made by the Id. AO/TPO, are grossly injudicious, unwarranted, against the facts of the case and bad in law. 2. The additions/disallowances made are unsustainable, unjust

PLANT LIPIDS (P) LTD.,KADAYIRUPPU vs. DCIT , CORPORATE CIRCLE-2(1), KOCHI

In the result appeal filed by assessee stands allowed

ITA 598/COCH/2024[2020-21]Status: DisposedITAT Cochin19 May 2025AY 2020-21

Bench: Shri Inturi Rama Rao & Shri Keshav Dubeyassessmentyear:2020-21 Plant Lipids (P) Ltd. Kadayiruppu Po Kolenchery Dcit, Vs. Kerala 682 311 Corporate Circle-2(1) Kochi Pan No : Aabcp6061C Appellant Respondent Appellant By : Shri Thomson Thomas, A.R. Respondent By : Shri Sanjit Kumar Das, D.R. Date Of Hearing : 20.02.2025 Date Of Pronouncement : 19.05.2025 O R D E R Perkeshav Dubey: This Appeal At The Instance Of The Assessee Is Directed Against The Order Of The Ao, Assessment Unit, Income Tax Department Dated 19.6.2024 Vide Din No.Itba/Ast/S/143(3)/2024- 25/1065876641(1) For The Ay 2020-21 Passed U/S 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income Tax Act, 1961 (In Short “The Act”). 2. The Assessee Has Raised Following Grounds Of Appeal: Plant Lipids (P) Ltd., Kolencherry, Kerala Page 2 Of 8

For Appellant: Shri Thomson Thomas, A.RFor Respondent: Shri Sanjit Kumar Das, D.R
Section 143(3)Section 144(1)Section 144CSection 80GSection 92C

Transfer Pricing Order made an adjustment of Rs.2,03,38,752/- towards notional guarantee commission in respect of corporate guarantee given by the assessee for its Subsidiary.After receiving the order of the TPO, the Assessing Officer made a draft assessment order u/s 144(1) proposing to make the following adjustments:- i. Addition as proposed by TPO — towards notional Guarantee Commission