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69 results for “transfer pricing”+ Section 155clear

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Key Topics

Section 250115Section 9(1)(vii)20Addition to Income7Section 53A6Section 2015Section 1955Section 9(1)(i)5Exemption5Double Taxation/DTAA

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

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)

155 shall, as far as may be, apply in relation to the stamp duty value of such property for the purpose of sub-clause (b) as they apply for valuation of capital asset under those sections : Provided further that this clause shall not apply to any sum of money or any property received— (a) from any relative

Showing 1–20 of 69 · Page 1 of 4

5
TDS5
Section 1324
Section 153A4

THE ACIT, COCHIN vs. M/S.SUD CHEMIE INDIA P. LTD, COCHIN

In the result, the appeals of the Revenue are partly allowed for statistical

ITA 41/COCH/2017[2010-11]Status: DisposedITAT Cochin26 Feb 2018AY 2010-11

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

price below cost is allowed even though such loss has not been realized actually. At this stage, we need to emphasise once again that the above system of commercial accounting can be superseded or modified by legislative enactment. This is where s. 145(2) comes into play. Under that section, the Central Government is empowered to notify from time

THE ACIT, COCHIN vs. M/S.SUD CHEMIE INDIA P. LTD, ALUVA

In the result, the appeals of the Revenue are partly allowed for statistical

ITA 3/COCH/2017[2008-09]Status: DisposedITAT Cochin26 Feb 2018AY 2008-09

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

price below cost is allowed even though such loss has not been realized actually. At this stage, we need to emphasise once again that the above system of commercial accounting can be superseded or modified by legislative enactment. This is where s. 145(2) comes into play. Under that section, the Central Government is empowered to notify from time

COCHIN INTERNATIONAL AIRPORT LIMITED,COCHIN vs. DCIT CORPORATE CIRCLE 1(1), COCHIN

In the result, all the appeals filed by the assessee are allowed

ITA 724/COCH/2023[2009-10]Status: DisposedITAT Cochin23 Sept 2025AY 2009-10

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.

For Appellant: Shri Gopi K, CAFor Respondent: Shri Omanakuttan, Snr. AR
Section 195Section 201Section 9(1)(i)Section 9(1)(vii)

section 9(1)(vii) of the Act. If the said payment would fall u/s. 9(1)(vii), whether the said payments are eligible for exemption as per the DTAA. Finally, the AO arrived the conclusion that the non-residents do not have any business connection and PE in India. The AO further held that the fees payable to the said

COCHIN INTERNATIONAL AIRPORT LIMITED,COCHIN vs. DCIT CORPORATE CIRCLE 1(1), COCHIN

In the result, all the appeals filed by the assessee are allowed

ITA 721/COCH/2023[2006-07]Status: DisposedITAT Cochin23 Sept 2025AY 2006-07

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.

For Appellant: Shri Gopi K, CAFor Respondent: Shri Omanakuttan, Snr. AR
Section 195Section 201Section 9(1)(i)Section 9(1)(vii)

section 9(1)(vii) of the Act. If the said payment would fall u/s. 9(1)(vii), whether the said payments are eligible for exemption as per the DTAA. Finally, the AO arrived the conclusion that the non-residents do not have any business connection and PE in India. The AO further held that the fees payable to the said

COCHIN INTERNATIONAL AIRPORT LIMITED,COCHIN vs. DCIT CORPORATE CIRCLE 1(1), COCHIN

In the result, all the appeals filed by the assessee are allowed

ITA 723/COCH/2023[2008-09]Status: DisposedITAT Cochin23 Sept 2025AY 2008-09

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.

For Appellant: Shri Gopi K, CAFor Respondent: Shri Omanakuttan, Snr. AR
Section 195Section 201Section 9(1)(i)Section 9(1)(vii)

section 9(1)(vii) of the Act. If the said payment would fall u/s. 9(1)(vii), whether the said payments are eligible for exemption as per the DTAA. Finally, the AO arrived the conclusion that the non-residents do not have any business connection and PE in India. The AO further held that the fees payable to the said

COCHIN INTERNATIONAL AIRPORT LIMITED,COCHIN vs. DCIT CORPORATE CIRCLE 1(1), COCHIN

ITA 722/COCH/2023[2007-08]Status: DisposedITAT Cochin23 Sept 2025AY 2007-08

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.

For Appellant: Shri Gopi K, САFor Respondent: Shri Omanakuttan, Snr. AR
Section 195Section 201Section 9(1)(i)Section 9(1)(vii)

section 9(1)(vii) of the Act. If the said payment would fall u/s. 9(1)(vii), whether the said payments are eligible for exemption as per the DTAA. Finally, the AO arrived the conclusion that the non-residents do not have any business connection and PE in India. The AO further held that the fees payable to the said

COCHIN INTERNATIONAL AIRPORT LIMITED,COCHIN vs. DCIT CORPORATE CIRCLE 1(1), COCHIN

ITA 720/COCH/2023[2005-06]Status: DisposedITAT Cochin23 Sept 2025AY 2005-06

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.

For Appellant: Shri Gopi K, CAFor Respondent: Shri Omanakuttan, Snr. AR
Section 195Section 201Section 9(1)(i)Section 9(1)(vii)

section 9(1)(vii) of the Act. If the said payment would fall u/s. 9(1)(vii), whether the said payments are eligible for exemption as per the DTAA. Finally, the AO arrived the conclusion that the non-residents do not have any business connection and PE in India. The AO further held that the fees payable to the said

ABC BUILDWARES(P) LIMITED,KANNUR vs. ACIT, CENTRAL CIRCLE-1`, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 455/COCH/2024[2018-2019]Status: DisposedITAT Cochin20 Dec 2024AY 2018-2019

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

K.ABDUL VAHEED,TALIPARAMBA vs. ACIT(CENTRAL CIRCLE-1), KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 501/COCH/2024[2017-18]Status: DisposedITAT Cochin20 Dec 2024AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

ABC BUILDWARES INDIA(P) LIMITED,KANNUR vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 454/COCH/2024[2017-2018]Status: DisposedITAT Cochin20 Dec 2024AY 2017-2018

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

KAKKOTTAKATH NADUVILAPURAYIL JUNAID,KANNUR vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 497/COCH/2024[2017-2018]Status: DisposedITAT Cochin20 Dec 2024AY 2017-2018

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

KAKKOTTAKATH NADUVILAPURAYIL JUNAID,KANNUR vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 498/COCH/2024[2018-2019]Status: DisposedITAT Cochin20 Dec 2024AY 2018-2019

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

KAKKOTTAKATH NADUVILAPURAYIL JUNAID,KANNUR vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 500/COCH/2024[2020-2021]Status: DisposedITAT Cochin20 Dec 2024AY 2020-2021

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

RUCHIT PARIMAL ASHAR,SANALA ROAD, MORBI vs. ACIT CENTRAL CIRCLE-1, CALICUT

In the result, appeal of the assessee is hereby dismissed

ITA 505/COCH/2024[2018-19]Status: DisposedITAT Cochin20 Dec 2024AY 2018-19

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

KAKKOTTAKATH NADUVILAPURAYIL JUNAID,KANNUR vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 499/COCH/2024[2019-2020]Status: DisposedITAT Cochin20 Dec 2024AY 2019-2020

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

KODIYIL MUHAMMED MADANI PARTNER, ABC SALES CORPORATION,TALIPARAMBA vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 836/COCH/2024[2019-20]Status: DisposedITAT Cochin20 Dec 2024AY 2019-20

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

K.ABDUL VAHEED,TALIPARAMBA vs. ACIT CENTRAL CIRCLE-1, , KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 502/COCH/2024[2018-19]Status: DisposedITAT Cochin20 Dec 2024AY 2018-19

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

A B C SALES CORPORATION ,KANNUR vs. ITO, CIRCLE-1, KANNUR

In the result, appeal of the assessee is hereby dismissed

ITA 404/COCH/2024[2017-2018]Status: DisposedITAT Cochin20 Dec 2024AY 2017-2018

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming

KODIYIL MUHAMMED MADANI, PARTNER(ABC SALAES CORPORATION),TALIPARAMBA vs. ACIT , CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 523/COCH/2024[2013-14]Status: DisposedITAT Cochin20 Dec 2024AY 2013-14

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

Section 145(3) of the Income Tax Act, which apply in cases of discrepancies in the books of accounts, were not invoked in this case. Therefore, we set aside the findings of the learned CIT(A) and direct the Assessing Officer to delete the addition made by him. Consequently, the assessee’s ground of appeal is hereby allowed. 56. Coming