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124 results for “transfer pricing”+ Section 147clear

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Key Topics

Section 25096Addition to Income35Section 26319Section 143(3)13Capital Gains12Exemption12Section 10(37)8Section 2(24)(vi)8Section 488

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)

Section 92C(3) of the Act supported the contention of the Assessee that the TP documentation of the Assessee was rejected without appreciating the documents/submissions filed by the Assessee. 6.1. It was submitted that segmental information was submitted before the TPO alongwith Response, dated 20/09/2023, whereby it was explained/clarified by the Assessee as under: (a) The basis of segmenting each

SILLS KARINGATTIL JOSE,NEDUMKANDOM vs. ITO WARD 2, THODUPUZHA

Showing 1–20 of 124 · Page 1 of 7

Section 153A6
Section 143(1)4
Long Term Capital Gains4

Appeal is partly allowed for statistical purpose

ITA 132/COCH/2023[2016-17]Status: DisposedITAT Cochin19 Nov 2024AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singhsils Karingattil Jose Income Tax Officer Np 3/406, Karingattil Ward - 2, House, Munnar Road Thodupuzha Vs. Nedumkandom P.O. [Pan: Afopj8789C] (Appellant) (Respondent)

For Appellant: Shri P. M. Veeramani, CAFor Respondent: Smt. V. Swarnalatha, Sr. D.R
Section 2(47)Section 2(47)(V)Section 250Section 50CSection 53ASection 56(2)(vii)

147 of the Income Tax Act for the difference of Rs. 11,67,900/- as escapement of income. 5.2 During the assessment proceedings, the appellant argued that the valuation of shares has been done through 4 Sils Karingattil Jose DCF method. The appellant also submitted the valuation report. The Assessing Officer found that it is not backed by any documentary

SRI. ELDHOSE K. VARGHESE,MUVATTUPUZHA vs. THEDCIT, ERNAKULAM

In the result, appeals for assessment year 2006-07 to 2008-09 and 2010-11 are allowed while the appeals of the assessee for assessment year 2009-10, 2011-12 and 2012-13 are partly allowed

ITA 261/COCH/2016[2006-07]Status: DisposedITAT Cochin03 Oct 2017AY 2006-07

Bench: Shri P. K. Bansal & Shri George George K.

Section 132Section 143(1)Section 143(2)Section 153ASection 153CSection 234A

147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person other than the person referred to in section 153A, then the books of account or documents or assets

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

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 kernels remained constant throughout the year so that the basis of sale price could be arrived at. The sale price

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

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 kernels remained constant throughout the year so that the basis of sale price could be arrived at. The sale price

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

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 kernels remained constant throughout the year so that the basis of sale price could be arrived at. The sale price

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

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 kernels remained constant throughout the year so that the basis of sale price could be arrived at. The sale price

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

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 kernels remained constant throughout the year so that the basis of sale price could be arrived at. The sale price

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

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 kernels remained constant throughout the year so that the basis of sale price could be arrived at. The sale price

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

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 kernels remained constant throughout the year so that the basis of sale price could be arrived at. The sale price

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

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 kernels remained constant throughout the year so that the basis of sale price could be arrived at. The sale price

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

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 kernels remained constant throughout the year so that the basis of sale price could be arrived at. The sale price

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

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 kernels remained constant throughout the year so that the basis of sale price could be arrived at. The sale price

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

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 kernels remained constant throughout the year so that the basis of sale price could be arrived at. The sale price

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

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 kernels remained constant throughout the year so that the basis of sale price could be arrived at. The sale price

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

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 kernels remained constant throughout the year so that the basis of sale price could be arrived at. The sale price

M/S.US TECHNOLOGY INTERNATIONAL P. LTD,TRIVANDRUM vs. THE JCIT, TRIVANDRUM

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

ITA 247/COCH/2017[2009-10]Status: DisposedITAT Cochin23 Jul 2018AY 2009-10

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.M.Raghunathan SFor Respondent: Sri.Santam Bose
Section 10ASection 10BSection 143(1)Section 143(3)Section 144CSection 263

transfer pricing adjustment in the draft assessment order. The final assessment order was passed on 26.04.2013. The assessee, however, claims that the final assessment order was not received by it. Thereafter reassessment notice was issued and orders u/s 143(3) r.w.s. 147 of the I.T.Act was passed on 27.03.2015. The Assessing Officer in the reassessment completed, disallowed the amount claimed

THE ACIT, CIRCLE-1(1), ERNAKULAM, ERNAKULAM vs. SRI.E.M.PAUL, EDAKATTUKUDIYIL, KOTHAMANGALAM

In the result, the appeal of the assessee is partly allowed and the appeals

ITA 449/COCH/2007[1999-2000]Status: DisposedITAT Cochin17 Jan 2019AY 1999-2000

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

Section 2(24)(vi)Section 48

Section 147 on the differential total income of Rs.3,88,83,800/-. The assessee carried the matter in appeal before the Commissioner of Income Tax (Appeals), who confirmed the order of assessment. The matter was carried in appeal to the Tribunal and by the impugned order, the Tribunal allowed the appeal of the assessee, accepting the sale value as returned

THE ITO, WARD-2, THODUPUZHA, THODUPUZHA vs. SRI.MARTIN JOHNY, KOTHAMANGALAM

In the result, the appeal of the assessee is partly allowed and the appeals

ITA 354/COCH/2006[1999-2000]Status: DisposedITAT Cochin17 Jan 2019AY 1999-2000

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

Section 2(24)(vi)Section 48

Section 147 on the differential total income of Rs.3,88,83,800/-. The assessee carried the matter in appeal before the Commissioner of Income Tax (Appeals), who confirmed the order of assessment. The matter was carried in appeal to the Tribunal and by the impugned order, the Tribunal allowed the appeal of the assessee, accepting the sale value as returned

THE ITO, WD-2, THODUPUZHA, THODUPUZHA vs. SRI.E.J.SONY, KOTHAMANGALAM

In the result, the appeal of the assessee is partly allowed and the appeals

ITA 355/COCH/2006[1999-2000]Status: DisposedITAT Cochin17 Jan 2019AY 1999-2000

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

Section 2(24)(vi)Section 48

Section 147 on the differential total income of Rs.3,88,83,800/-. The assessee carried the matter in appeal before the Commissioner of Income Tax (Appeals), who confirmed the order of assessment. The matter was carried in appeal to the Tribunal and by the impugned order, the Tribunal allowed the appeal of the assessee, accepting the sale value as returned