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87 results for “transfer pricing”+ Section 153(3)clear

Sorted by relevance

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Key Topics

Section 250120Addition to Income19Exemption14Section 220(2)12Section 15412Section 244A12Section 26310Section 1539Section 14A8

M/S.KERA FIBERTEX INTERNATIONAL P. LTD,COCHIN vs. THE ACIT, COCHIN

In the result, the appeals by the assessee is allowed, and that by the Revenue, dismissed

ITA 311/COCH/2015[2009-10]Status: DisposedITAT Cochin30 Oct 2023AY 2009-10

Bench: Shri Sanjay Arora (Accountant Member), Shri Manomohan Das (Judicial Member)

For Appellant: Shri P. Sathisan, AdvocateFor Respondent: Shri Sajit Kumar Das, CIT-DR
Section 143(3)Section 144CSection 144C(2)Section 153Section 153B

153 or section 153B, the assessment without providing any further opportunity of being heard to the assessee, within one month from the end of the month in which such direction is received. (14)… Page 3 ITANos. 311 & 361/Coch/ 2015 (AY 2009-10) Kera Fibertex International P. Ltd. vs. Asst. CIT (15) For the purposes of this section,— (a) "Dispute Resolution

Showing 1–20 of 87 · Page 1 of 5

Section 143(3)6
Disallowance6
Rectification u/s 1546

THE ACIT CORPORATE, COCHIN vs. M/S.KERA FIBERTEX INTERNATIONAL P. LTD, COCHIN

In the result, the appeals by the assessee is allowed, and that by the Revenue, dismissed

ITA 361/COCH/2015[2009-10]Status: DisposedITAT Cochin30 Oct 2023AY 2009-10

Bench: Shri Sanjay Arora (Accountant Member), Shri Manomohan Das (Judicial Member)

For Appellant: Shri P. Sathisan, AdvocateFor Respondent: Shri Sajit Kumar Das, CIT-DR
Section 143(3)Section 144CSection 144C(2)Section 153Section 153B

153 or section 153B, the assessment without providing any further opportunity of being heard to the assessee, within one month from the end of the month in which such direction is received. (14)… Page 3 ITANos. 311 & 361/Coch/ 2015 (AY 2009-10) Kera Fibertex International P. Ltd. vs. Asst. CIT (15) For the purposes of this section,— (a) "Dispute Resolution

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

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 seized or requisitioned shall be handed over

M/S ASPINWALL & CO.,LTD,COCHIN vs. THE ACIT, COCHIN

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

ITA 128/COCH/2017[2012-13]Status: DisposedITAT Cochin19 May 2020AY 2012-13

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

Section 14A

3) Harrisons Malayalam Limited vs. DCIT (24 taxmann.com 59) (Kochi Trib.) 4) CIT vs. Rajagiri Rubber & Produce Co. Ltd. (189 ITR 182) (Ker.) I.T.A. Nos. 60&61/Coch/2015 & 128 & 133/Coch/2017 8.6 The Ld. DR submitted that decision relied upon by the assessee was given in an entirely different context. At that point of time income form value added rubber was never

ASPINWALL & COMPANY LTD,COCHIN vs. THE ACIT, COCHIN

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

ITA 61/COCH/2015[2006-07]Status: DisposedITAT Cochin19 May 2020AY 2006-07

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

Section 14A

3) Harrisons Malayalam Limited vs. DCIT (24 taxmann.com 59) (Kochi Trib.) 4) CIT vs. Rajagiri Rubber & Produce Co. Ltd. (189 ITR 182) (Ker.) I.T.A. Nos. 60&61/Coch/2015 & 128 & 133/Coch/2017 8.6 The Ld. DR submitted that decision relied upon by the assessee was given in an entirely different context. At that point of time income form value added rubber was never

THE DCIT, COCHIN vs. M/S.ASPINWALL & CO. LTD, COCHIN

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

ITA 133/COCH/2017[2012-13]Status: DisposedITAT Cochin19 May 2020AY 2012-13

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

Section 14A

3) Harrisons Malayalam Limited vs. DCIT (24 taxmann.com 59) (Kochi Trib.) 4) CIT vs. Rajagiri Rubber & Produce Co. Ltd. (189 ITR 182) (Ker.) I.T.A. Nos. 60&61/Coch/2015 & 128 & 133/Coch/2017 8.6 The Ld. DR submitted that decision relied upon by the assessee was given in an entirely different context. At that point of time income form value added rubber was never

ASPINWALL & COMPANY LTD,COCHIN vs. THE ACIT, COCHIN

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

ITA 60/COCH/2015[2006-07]Status: DisposedITAT Cochin19 May 2020AY 2006-07

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

Section 14A

3) Harrisons Malayalam Limited vs. DCIT (24 taxmann.com 59) (Kochi Trib.) 4) CIT vs. Rajagiri Rubber & Produce Co. Ltd. (189 ITR 182) (Ker.) I.T.A. Nos. 60&61/Coch/2015 & 128 & 133/Coch/2017 8.6 The Ld. DR submitted that decision relied upon by the assessee was given in an entirely different context. At that point of time income form value added rubber was never

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

3) Timing of contracts & price variation even among superior grades. (4) Exchange rate variation. Accordingly, at least 10% allowance to account for such factors as composition of grades in the sales mix, quality of kernels, etc. and 5% allowance to cover Profit and indirect overheads of sister concern(s), if considered, then no addition is warranted.For this, reliance is placed

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

3) Timing of contracts & price variation even among superior grades. (4) Exchange rate variation. Accordingly, at least 10% allowance to account for such factors as composition of grades in the sales mix, quality of kernels, etc. and 5% allowance to cover Profit and indirect overheads of sister concern(s), if considered, then no addition is warranted.For this, reliance is placed

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

3) Timing of contracts & price variation even among superior grades. (4) Exchange rate variation. Accordingly, at least 10% allowance to account for such factors as composition of grades in the sales mix, quality of kernels, etc. and 5% allowance to cover Profit and indirect overheads of sister concern(s), if considered, then no addition is warranted.For this, reliance is placed

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

3) Timing of contracts & price variation even among superior grades. (4) Exchange rate variation. Accordingly, at least 10% allowance to account for such factors as composition of grades in the sales mix, quality of kernels, etc. and 5% allowance to cover Profit and indirect overheads of sister concern(s), if considered, then no addition is warranted.For this, reliance is placed

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

3) Timing of contracts & price variation even among superior grades. (4) Exchange rate variation. Accordingly, at least 10% allowance to account for such factors as composition of grades in the sales mix, quality of kernels, etc. and 5% allowance to cover Profit and indirect overheads of sister concern(s), if considered, then no addition is warranted.For this, reliance is placed

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

3) Timing of contracts & price variation even among superior grades. (4) Exchange rate variation. Accordingly, at least 10% allowance to account for such factors as composition of grades in the sales mix, quality of kernels, etc. and 5% allowance to cover Profit and indirect overheads of sister concern(s), if considered, then no addition is warranted.For this, reliance is placed

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

3) Timing of contracts & price variation even among superior grades. (4) Exchange rate variation. Accordingly, at least 10% allowance to account for such factors as composition of grades in the sales mix, quality of kernels, etc. and 5% allowance to cover Profit and indirect overheads of sister concern(s), if considered, then no addition is warranted.For this, reliance is placed

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

3) Timing of contracts & price variation even among superior grades. (4) Exchange rate variation. Accordingly, at least 10% allowance to account for such factors as composition of grades in the sales mix, quality of kernels, etc. and 5% allowance to cover Profit and indirect overheads of sister concern(s), if considered, then no addition is warranted.For this, reliance is placed

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

3) Timing of contracts & price variation even among superior grades. (4) Exchange rate variation. Accordingly, at least 10% allowance to account for such factors as composition of grades in the sales mix, quality of kernels, etc. and 5% allowance to cover Profit and indirect overheads of sister concern(s), if considered, then no addition is warranted.For this, reliance is placed

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

3) Timing of contracts & price variation even among superior grades. (4) Exchange rate variation. Accordingly, at least 10% allowance to account for such factors as composition of grades in the sales mix, quality of kernels, etc. and 5% allowance to cover Profit and indirect overheads of sister concern(s), if considered, then no addition is warranted.For this, reliance is placed

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

3) Timing of contracts & price variation even among superior grades. (4) Exchange rate variation. Accordingly, at least 10% allowance to account for such factors as composition of grades in the sales mix, quality of kernels, etc. and 5% allowance to cover Profit and indirect overheads of sister concern(s), if considered, then no addition is warranted.For this, reliance is placed

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

3) Timing of contracts & price variation even among superior grades. (4) Exchange rate variation. Accordingly, at least 10% allowance to account for such factors as composition of grades in the sales mix, quality of kernels, etc. and 5% allowance to cover Profit and indirect overheads of sister concern(s), if considered, then no addition is warranted.For this, reliance is placed

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

3) Timing of contracts & price variation even among superior grades. (4) Exchange rate variation. Accordingly, at least 10% allowance to account for such factors as composition of grades in the sales mix, quality of kernels, etc. and 5% allowance to cover Profit and indirect overheads of sister concern(s), if considered, then no addition is warranted.For this, reliance is placed