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174 results for “transfer pricing”+ Section 24clear

Sorted by relevance

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Key Topics

Section 25093Addition to Income37Section 80G16Section 143(3)15Capital Gains15Section 26311Section 80G(5)10Disallowance10Section 2(24)(vi)

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

Section 92B of the Act. We also reject the contention of the Assessee that continuing debit balance of short term advances did not constitute an ‘International Transaction’. Therefore, Ground No. 4.1 raised by the Assessee is dismissed. 5.3. During the assessment proceedings the TPO noted that the Assessee was providing loans and advances to its AEs and was not charging

Showing 1–20 of 174 · Page 1 of 9

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8
Section 488
Section 153A7
Business Income6

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)

24), to include the value of such shares in the definition of income ; (ii) section 49, to provide that the cost of acquisition of such shares will be the value which has been taken into account and has been subjected to tax under the provisions of section 56(2). These amendments are proposed to take effect from 1st June

SHRI.PRAKASH R. NAIR,KOLLAM vs. DCIT, KOLLAM

In the result, the assessee’s appeal is partly allowed for statistical purposes

ITA 141/COCH/2021[2000-2001]Status: DisposedITAT Cochin17 Jan 2024AY 2000-2001

Bench: Shri Sanjay Arora & Shri Manomohan Dasprakash R. Nair Dy.Cit, Central Circle Prop. Dhanya Foods Kollam Kochuppilammoodu Vs. Kollam 691001 [Pan:Abfpn4424P] (Appellant) (Respondent)

For Appellant: Shri R. Vijayaraghavan, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 143(1)Section 148(1)Section 271(1)(c)Section 274Section 80Section 801A(9)Section 80HSection 80I

24,30,582/- averaging to Rs. 205 per kg. If Andhra Pradesh transfers alone were taken into consideration, the value of 30593 tins was Rs. 6,10,06,722/-. This gives an average price of Rs. 176 per kg. The break-up of the original transfers unit-wise is enclosed. On perusal, you will please appreciate that many

US TECHNOLOGY INTERNATIONAL P. LTD,TRIVANDRUM vs. THE ACIT, TRIVANDRUM

In the result, appeal filed by the assessee is partly allowed of statistical purposes

ITA 562/COCH/2022[2017-2018]Status: DisposedITAT Cochin21 Oct 2024AY 2017-2018

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Us Technology International Pvt. Ltd. Acit, Circle - 1(1) 621, Nila, Technopark Campus 1St Floor, Aayakar Bhavan Vs. Kariyavattom, Trivandrum 695581 Kowdiar [Pan: Aaacu5628B] Thiruvananthapuram 695003 (Appellant) (Respondent)

For Appellant: Shri Rajakannan, AdvocateFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 144C(3)Section 92C(3)

section 234B and 234C of the Act The Appellant craves leave to add to or alter, by deletion, substitution, modification or otherwise, the above grounds of appeal, either before or during the hearing of the appeal.” 3. At the outset, we note that the learned AR for the assessee before us submitted that issue raised by the assessee in ground

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 prices. For example when price of say W320 grade contracted earlier was Rs. X which is less than cost or current price, assessee is bound to sell atcontracted price only. It was submitted that A.O. wrongly presumed that entire sales in India were to sister concerns. The sales wereeffected in the domestic market through depots, consignment agents

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 prices. For example when price of say W320 grade contracted earlier was Rs. X which is less than cost or current price, assessee is bound to sell atcontracted price only. It was submitted that A.O. wrongly presumed that entire sales in India were to sister concerns. The sales wereeffected in the domestic market through depots, consignment agents

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 prices. For example when price of say W320 grade contracted earlier was Rs. X which is less than cost or current price, assessee is bound to sell atcontracted price only. It was submitted that A.O. wrongly presumed that entire sales in India were to sister concerns. The sales wereeffected in the domestic market through depots, consignment agents

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 prices. For example when price of say W320 grade contracted earlier was Rs. X which is less than cost or current price, assessee is bound to sell atcontracted price only. It was submitted that A.O. wrongly presumed that entire sales in India were to sister concerns. The sales wereeffected in the domestic market through depots, consignment agents

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 prices. For example when price of say W320 grade contracted earlier was Rs. X which is less than cost or current price, assessee is bound to sell atcontracted price only. It was submitted that A.O. wrongly presumed that entire sales in India were to sister concerns. The sales wereeffected in the domestic market through depots, consignment agents

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 prices. For example when price of say W320 grade contracted earlier was Rs. X which is less than cost or current price, assessee is bound to sell atcontracted price only. It was submitted that A.O. wrongly presumed that entire sales in India were to sister concerns. The sales wereeffected in the domestic market through depots, consignment agents

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 prices. For example when price of say W320 grade contracted earlier was Rs. X which is less than cost or current price, assessee is bound to sell atcontracted price only. It was submitted that A.O. wrongly presumed that entire sales in India were to sister concerns. The sales wereeffected in the domestic market through depots, consignment agents

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 prices. For example when price of say W320 grade contracted earlier was Rs. X which is less than cost or current price, assessee is bound to sell atcontracted price only. It was submitted that A.O. wrongly presumed that entire sales in India were to sister concerns. The sales wereeffected in the domestic market through depots, consignment agents

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 prices. For example when price of say W320 grade contracted earlier was Rs. X which is less than cost or current price, assessee is bound to sell atcontracted price only. It was submitted that A.O. wrongly presumed that entire sales in India were to sister concerns. The sales wereeffected in the domestic market through depots, consignment agents

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 prices. For example when price of say W320 grade contracted earlier was Rs. X which is less than cost or current price, assessee is bound to sell atcontracted price only. It was submitted that A.O. wrongly presumed that entire sales in India were to sister concerns. The sales wereeffected in the domestic market through depots, consignment agents

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 prices. For example when price of say W320 grade contracted earlier was Rs. X which is less than cost or current price, assessee is bound to sell atcontracted price only. It was submitted that A.O. wrongly presumed that entire sales in India were to sister concerns. The sales wereeffected in the domestic market through depots, consignment agents

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 prices. For example when price of say W320 grade contracted earlier was Rs. X which is less than cost or current price, assessee is bound to sell atcontracted price only. It was submitted that A.O. wrongly presumed that entire sales in India were to sister concerns. The sales wereeffected in the domestic market through depots, consignment agents

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 prices. For example when price of say W320 grade contracted earlier was Rs. X which is less than cost or current price, assessee is bound to sell atcontracted price only. It was submitted that A.O. wrongly presumed that entire sales in India were to sister concerns. The sales wereeffected in the domestic market through depots, consignment agents

M/S.APOLLO TYRES LTD,COCHIN vs. THE PRINCIPAL COMMISSIONER OF INCOMETAX, COCHIN

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

ITA 609/COCH/2017[2013-14]Status: DisposedITAT Cochin01 Sept 2025AY 2013-14

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm Assessment Year: 2013-14 Apollo Tyres Ltd. .......... Appellant 3Rd Floor, Areekal Mansion, Panampilly Nagar, Kochi 682036 [Pan: Aaaca6990Q] Vs. Dcit, 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: 01.09.2025

For Appellant: Shri Abraham Joseph Markos, AdvFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 115JSection 143(3)Section 32Section 32(1)(iia)Section 35Section 43(1)Section 92C

Transfer Pricing Officer (TPO) u/s. 92CA(1) of the Act for the purpose of benchmarking the above international transactions. The TPO vide order dated 28.10.2016 3 Apollo Tyres Ltd. passed u/s. 92CA(3) of the Act suggested upward TP adjustments in respect of corporate guarantee commission provided to Apollo Vredestein BV (AVBV

THE JT CIT, TRIVANDRUM vs. ALLIANZ CORNHILL INFORMATION SERVICES P. LTD, TRIVANDRUM

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

ITA 185/COCH/2015[2010-11]Status: DisposedITAT Cochin20 Dec 2019AY 2010-11

Bench: S/Shri Chandra Poojari, Am & George George K., Jm Assessment Year : 2010-11

Section 10BSection 144C(5)Section 92C(2)

transfer pricing purposes are computed based on the books and not based on tax books and the prior period income was accounted in the books only in FY 2009-10 and hence, must be considered in this year. According to the Ld. AR, the Company had disclosed the said prior period income in the Form 3CEB

M/S.ALLIANZ CORNHILL INFORMATION SERVICES P. LTD,TRIVANDRUM vs. JTCIT, TRIVANDRUM

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

ITA 191/COCH/2015[2010-11]Status: DisposedITAT Cochin20 Dec 2019AY 2010-11

Bench: S/Shri Chandra Poojari, Am & George George K., Jm Assessment Year : 2010-11

Section 10BSection 144C(5)Section 92C(2)

transfer pricing purposes are computed based on the books and not based on tax books and the prior period income was accounted in the books only in FY 2009-10 and hence, must be considered in this year. According to the Ld. AR, the Company had disclosed the said prior period income in the Form 3CEB