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152 results for “transfer pricing”+ Section 2(31)clear

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Key Topics

Section 25092Addition to Income37Section 143(3)12Section 80G12Capital Gains12Section 92C11Disallowance9Section 2638Section 2(24)(vi)8

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)

prices much below their fair market value, it is proposed to amend section 56 to also include within its ambit transactions undertaken in shares of a company (not being a company in which public are substantially interested) either for inadequate consideration or without consideration where the recipient is a firm or a company (not being a company in which public

Showing 1–20 of 152 · Page 1 of 8

...
Section 488
Transfer Pricing8
Section 327

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)

2%-7% in the next 6 months, driven by delays in decision making by businesses, as they evaluate the impact of COVID-19 on operations In March 2020, Accenture, a tech-consulting firm, lowered its FY 2020 revenue growth forecast from 6-8% to 3-6% because of the impact of COVID-19. Indian IT firms are expected to follow

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

31) of section 10, is not includible in the total income. 8.5 The Ld. AR submitted that the above Rule covers incomes which are derived from the sale of certain items which are obtained from rubber plants grown. It was submitted that the above rule does not cover incomes which have been derived from the sale of the rubber plants/trees

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

31) of section 10, is not includible in the total income. 8.5 The Ld. AR submitted that the above Rule covers incomes which are derived from the sale of certain items which are obtained from rubber plants grown. It was submitted that the above rule does not cover incomes which have been derived from the sale of the rubber plants/trees

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

31) of section 10, is not includible in the total income. 8.5 The Ld. AR submitted that the above Rule covers incomes which are derived from the sale of certain items which are obtained from rubber plants grown. It was submitted that the above rule does not cover incomes which have been derived from the sale of the rubber plants/trees

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

31) of section 10, is not includible in the total income. 8.5 The Ld. AR submitted that the above Rule covers incomes which are derived from the sale of certain items which are obtained from rubber plants grown. It was submitted that the above rule does not cover incomes which have been derived from the sale of the rubber plants/trees

M/S.IBS SOFTWARE SERVICES P. LTD,TRIVANDRUM vs. THE DCIT, TRIVANDRUM

ITA 601/COCH/2017[2013-14]Status: DisposedITAT Cochin13 Nov 2025AY 2013-14

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Rajakannan, AdvocateFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)Section 144CSection 144C(5)Section 36(1)(iii)Section 36(1)(va)Section 92C

2. That the directions of the learned Panel and the consequent assessment order is bad in law and on facts while upholding the action of the learned Additional Commissioner of Income- tax, (Transfer Pricing). Kochi (learned Transfer Pricing Officer' or 'learned TPO) of making an adjustment of INR 310,952.334 to the transfer price of the Appellant's international transaction

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

CARMEL EDUCATIONAL TRUST,PATHANAMTHITTA vs. DCIT,CEN- CIRCLE,, KOTTAYAM

In the result, the appeals of the assesses in ITA no

ITA 308/COCH/2019[2008-09]Status: DisposedITAT Cochin30 Sept 2019AY 2008-09

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

section 2(24)(iia) of the Act. But such contribution received by the Trust or any other on behalf of the Trust can be considered as income of the Trust only and not as income of the recipient. 6.4 The CIT(A) directed the Assessing Officer to adopt the share of donation as per the seized material after deducting

CARMEL EDUCATIONAL TRUST,PATHANAMTHITTA vs. DCIT,CEN- CIRCLE,, KOTTAYAM

In the result, the appeals of the assesses in ITA no

ITA 310/COCH/2019[2010-11]Status: DisposedITAT Cochin30 Sept 2019AY 2010-11

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

section 2(24)(iia) of the Act. But such contribution received by the Trust or any other on behalf of the Trust can be considered as income of the Trust only and not as income of the recipient. 6.4 The CIT(A) directed the Assessing Officer to adopt the share of donation as per the seized material after deducting

SRI.JOSE THOMAS,ADOOR vs. THE DCIT, CEN-CIRCLE, KOTTAYAM

In the result, the appeals of the assessesin ITA no

ITA 30/COCH/2019[2007-08]Status: DisposedITAT Cochin30 Sept 2019AY 2007-08

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

section 2(24)(iia) of the Act. But such contribution received by the Trust or any other on behalf of the Trust can be considered as income of the Trust only and not as income of the recipient. 6.4 The CIT(A) directed the Assessing Officer to adopt the share of donation as per the seized material after deducting

SMT.GRACY BABU,ADOOR P.O. vs. THE DCIT CEN-CIRCLE, KOTTAYAM

In the result, the appeals of the assessesin ITA no

ITA 35/COCH/2019[2009-10]Status: DisposedITAT Cochin30 Sept 2019AY 2009-10

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

section 2(24)(iia) of the Act. But such contribution received by the Trust or any other on behalf of the Trust can be considered as income of the Trust only and not as income of the recipient. 6.4 The CIT(A) directed the Assessing Officer to adopt the share of donation as per the seized material after deducting

CARMEL EDUCATIONAL TRUST,PATHANAMTHITTA vs. DCIT,CEN- CIRCLE,, KOTTAYAM

In the result, the appeals of the assesses in ITA no

ITA 305/COCH/2019[2005-06]Status: DisposedITAT Cochin30 Sept 2019AY 2005-06

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

section 2(24)(iia) of the Act. But such contribution received by the Trust or any other on behalf of the Trust can be considered as income of the Trust only and not as income of the recipient. 6.4 The CIT(A) directed the Assessing Officer to adopt the share of donation as per the seized material after deducting

SRI.JOSE THOMAS,ADOOR vs. THE DCIT, CEN-CIRCLE, KOTTAYAM

In the result, the appeals of the assessesin ITA no

ITA 28/COCH/2019[2005-06]Status: DisposedITAT Cochin30 Sept 2019AY 2005-06

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

section 2(24)(iia) of the Act. But such contribution received by the Trust or any other on behalf of the Trust can be considered as income of the Trust only and not as income of the recipient. 6.4 The CIT(A) directed the Assessing Officer to adopt the share of donation as per the seized material after deducting

SRI.JOSE THOMAS,ADOOR vs. THE DCIT, CEN-CIRCLE, KOTTAYAM

In the result, the appeals of the assessesin ITA no

ITA 31/COCH/2019[2009-10]Status: DisposedITAT Cochin30 Sept 2019AY 2009-10

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

section 2(24)(iia) of the Act. But such contribution received by the Trust or any other on behalf of the Trust can be considered as income of the Trust only and not as income of the recipient. 6.4 The CIT(A) directed the Assessing Officer to adopt the share of donation as per the seized material after deducting

SRI.JOSE THOMAS,ADOOR vs. THE DCIT, CEN-CIRCLE, KOTTAYAM

In the result, the appeals of the assessesin ITA no

ITA 29/COCH/2019[2006-07]Status: DisposedITAT Cochin30 Sept 2019AY 2006-07

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

section 2(24)(iia) of the Act. But such contribution received by the Trust or any other on behalf of the Trust can be considered as income of the Trust only and not as income of the recipient. 6.4 The CIT(A) directed the Assessing Officer to adopt the share of donation as per the seized material after deducting

CARMEL EDUCATIONAL TRUST,PATHANAMTHITTA vs. DCIT, KOTTAYAM

In the result, the appeals of the assesses in ITA no

ITA 304/COCH/2019[2004-05]Status: DisposedITAT Cochin30 Sept 2019AY 2004-05

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

section 2(24)(iia) of the Act. But such contribution received by the Trust or any other on behalf of the Trust can be considered as income of the Trust only and not as income of the recipient. 6.4 The CIT(A) directed the Assessing Officer to adopt the share of donation as per the seized material after deducting

SMT.GRACY BABU,ADOOR P.O. vs. THE DCIT CEN-CIRCLE, KOTTAYAM

In the result, the appeals of the assessesin ITA no

ITA 33/COCH/2019[2005-06]Status: DisposedITAT Cochin30 Sept 2019AY 2005-06

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

section 2(24)(iia) of the Act. But such contribution received by the Trust or any other on behalf of the Trust can be considered as income of the Trust only and not as income of the recipient. 6.4 The CIT(A) directed the Assessing Officer to adopt the share of donation as per the seized material after deducting

CARMEL EDUCATIONAL TRUST,PATHANAMTHITTA vs. DCIT,CEN- CIRCLE,, KOTTAYAM

In the result, the appeals of the assesses in ITA no

ITA 306/COCH/2019[2006-07]Status: DisposedITAT Cochin30 Sept 2019AY 2006-07

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

section 2(24)(iia) of the Act. But such contribution received by the Trust or any other on behalf of the Trust can be considered as income of the Trust only and not as income of the recipient. 6.4 The CIT(A) directed the Assessing Officer to adopt the share of donation as per the seized material after deducting

CARMEL EDUCATIONAL TRUST,PATHANAMTHITTA vs. DCIT,CEN- CIRCLE,, KOTTAYAM

In the result, the appeals of the assesses in ITA no

ITA 309/COCH/2019[2009-10]Status: DisposedITAT Cochin30 Sept 2019AY 2009-10

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

section 2(24)(iia) of the Act. But such contribution received by the Trust or any other on behalf of the Trust can be considered as income of the Trust only and not as income of the recipient. 6.4 The CIT(A) directed the Assessing Officer to adopt the share of donation as per the seized material after deducting