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90 results for “transfer pricing”+ Section 24clear

Sorted by relevance

Delhi1,566Mumbai1,555Hyderabad364Chennai320Bangalore283Ahmedabad228Jaipur205Chandigarh159Kolkata156Indore122Pune94Cochin90Rajkot72Surat50Visakhapatnam47Nagpur41Lucknow40Raipur37Cuttack33Amritsar24Agra22Guwahati19Jodhpur18Dehradun13Jabalpur8Patna6Varanasi6Allahabad4Ranchi3Panaji3

Key Topics

Section 250116Section 153A21Section 2(15)19Section 143(2)16Section 80G16Section 143(3)15Section 143(1)10Section 80G(5)10Addition to Income

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 90 · Page 1 of 5

10
Disallowance8
Exemption8
Reassessment7

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

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

SRI.K.P. JOHNY,THRISSUR vs. THE DCIT, CIRCLE-2(1), THRISSUR

In the result, both the assessee’s and the Revenue’s appeals are partly allowed and partly allowed for statistical purposes

ITA 206/COCH/2019[2014-15]Status: DisposedITAT Cochin09 Oct 2023AY 2014-15

Bench: Shri Sanjay Arora & Shri Manomohan Dask.P. Johny Asst. Cit, Manappuram House Circle – 2(1) Hospital Road, Chalakkudy Aayakar Bhavan Vs. Thrissur 680307 Sakthan Thampuran Nagar [Pan:Acgpj4958G] Thrissur 680001 (Appellant) (Respondent) Asst. Cit, K.P. Johny Circle – 2(1) Manappuram House Aayakar Bhavan Hospital Road, Chalakkudy Vs. Sakthan Thampuran Nagar Thrissur 680307 Thrissur 680001 [Pan: Acgpj4958G] (Appellant) (Respondent)

For Appellant: Shri T.M. Sreedharan, Sr. Advocate (with Smt. Divya Ravindran, Adv. with him)For Respondent: Smt. J.M. Jamuna Devi, Sr. DR
Section 131(1)Section 133ASection 147Section 148(1)Section 69

transfer of shares. (d) The receipt by way of allotment and purchase of shares is itself receipt of income to the extent of the excess value thereof over their acquisition cost, under section 2(24)(xv) of the Act. (e) There is no ‘short payment’ of sale consideration to the assessee, claimed at Rs.287.50 lakhs. The same is even otherwise

THE DCIT, CIRCLE-2(1), THRISSUR vs. SRI.K.P. JOHNY, THRISSUR

In the result, both the assessee’s and the Revenue’s appeals are partly allowed and partly allowed for statistical purposes

ITA 254/COCH/2019[2014-15]Status: DisposedITAT Cochin09 Oct 2023AY 2014-15

Bench: Shri Sanjay Arora & Shri Manomohan Dask.P. Johny Asst. Cit, Manappuram House Circle – 2(1) Hospital Road, Chalakkudy Aayakar Bhavan Vs. Thrissur 680307 Sakthan Thampuran Nagar [Pan:Acgpj4958G] Thrissur 680001 (Appellant) (Respondent) Asst. Cit, K.P. Johny Circle – 2(1) Manappuram House Aayakar Bhavan Hospital Road, Chalakkudy Vs. Sakthan Thampuran Nagar Thrissur 680307 Thrissur 680001 [Pan: Acgpj4958G] (Appellant) (Respondent)

For Appellant: Shri T.M. Sreedharan, Sr. Advocate (with Smt. Divya Ravindran, Adv. with him)For Respondent: Smt. J.M. Jamuna Devi, Sr. DR
Section 131(1)Section 133ASection 147Section 148(1)Section 69

transfer of shares. (d) The receipt by way of allotment and purchase of shares is itself receipt of income to the extent of the excess value thereof over their acquisition cost, under section 2(24)(xv) of the Act. (e) There is no ‘short payment’ of sale consideration to the assessee, claimed at Rs.287.50 lakhs. The same is even otherwise

MALANADU FARMERS SOCIETY ,KOTTAYAM vs. DCIT EXEMPTIONS, TVM, THIRUVANANTHAPURAM

The appeals of the assessees are allowed

ITA 632/COCH/2022[2017-2018]Status: DisposedITAT Cochin08 Mar 2023AY 2017-2018

Bench: Shri George George K. & Ms. Padmavathy S.

For Appellant: Shri Jose Kappan, CAFor Respondent: Shri Prashant V.K., CIT(DR)
Section 11Section 12ASection 143(1)Section 143(2)Section 2(15)Section 263

24,75,259/- for its objectives, ie for the welfare of the small and marginal farmers. (details enclosed Page No.70) The sales of the appellant are not in the nature of commercial receipts in the course of advancement of any other object of public utility as laid down in the proviso to Sec. 2(15), but these are receipts within

MALANADU MILK PRODUCERS SOCIETY,KOTTAYAM vs. DCIT, EXEMPTION, TVM, THIRUVANANTHAPURAM

The appeals of the assessees are allowed

ITA 633/COCH/2022[2017-2018]Status: DisposedITAT Cochin08 Mar 2023AY 2017-2018

Bench: Shri George George K. & Ms. Padmavathy S.

For Appellant: Shri Jose Kappan, CAFor Respondent: Shri Prashant V.K., CIT(DR)
Section 11Section 12ASection 143(1)Section 143(2)Section 2(15)Section 263

24,75,259/- for its objectives, ie for the welfare of the small and marginal farmers. (details enclosed Page No.70) The sales of the appellant are not in the nature of commercial receipts in the course of advancement of any other object of public utility as laid down in the proviso to Sec. 2(15), but these are receipts within

SONIYA DAVID LATHIKA,THIRUVANANTHAPURAM vs. ITO WARD 2(3), TRIVANDRUM, THIRUVANANTHAPURAM

In the result, the appeal filed by the assessee is allowed for statistical purpose

ITA 667/COCH/2022[2012-2013]Status: DisposedITAT Cochin07 Jun 2024AY 2012-2013

Bench: Shri Sanjay Arora, Am & Ms. Kavitha Rajagopal, Jm Soniya David Lathika The Ito, Ward-2(3) S. S. Nivas, Vizhinjam, Aayakar Bhavan, Kowdiar, Vs. Mukkola, Venganoor, Trivandrum-4 Thiruvananthapuram, Kerala Pan/Gir No. Ajqpl 8228 A (Assessee) : (Respondent)

For Appellant: Shri Adarsh BFor Respondent: 13.03.2024
Section 10(37)Section 250

price of Rs.3600000 including documentation. 4. The brief facts are that the assessee is an individual and during the year under consideration had sold 36.309 cents of land to the Managing Director of Vizhinjam International Seaport Ltd. (VISL for short) for a total consideration of Rs.99,90,865/- dated 10.08.2011 for providing infrastructure facility to VISL. 5. The learned Assessing

SANATANA DHARMA EDUCATIONAL AND CULTURAL SOCIETY,ALAPPUZHA vs. THE COMMISSIONER OF INCOME TAX (EXEMPTION), KOCHI, KOCHI

In the result, appeal of the assessee is allowed for statistical purpose

ITA 278/COCH/2024[2024-25]Status: DisposedITAT Cochin25 Sept 2024AY 2024-25

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Respondent: Shri Dr. S. Pandian, CIT-DR
Section 12A(1)(ac)Section 80GSection 80G(5)

transfers the property to A for the same price at which he originally purchased it, he should be liable to pay tax on the basis as if he has received the market value of the property as on the date of resale, if, in the mean- while, the market price has shot up and exceeds the agreed price by more

SANATANA DHARMA VIDYASALA,ALAPPUZHA vs. THE COMMISSIONER OF INCOME TAX (EXEMPTION), KOCHI, KOCHI

In the result, appeal of the assessee is allowed for statistical purpose

ITA 279/COCH/2024[2024-25]Status: DisposedITAT Cochin25 Sept 2024AY 2024-25

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Respondent: Shri Dr. S. Pandian, CIT-DR
Section 12A(1)(ac)Section 80GSection 80G(5)

transfers the property to A for the same price at which he originally purchased it, he should be liable to pay tax on the basis as if he has received the market value of the property as on the date of resale, if, in the mean- while, the market price has shot up and exceeds the agreed price by more

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

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

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 504/COCH/2024[2020-21]Status: DisposedITAT Cochin20 Dec 2024AY 2020-21

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

BATHX BATHWARE INDIA PRIVATE LIMITED,COCHIN vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 438/COCH/2024[2016-2017]Status: DisposedITAT Cochin20 Dec 2024AY 2016-2017

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

In the result, appeal of the assessee is hereby dismissed

ITA 456/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

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

In the result, appeal of the assessee is hereby dismissed

ITA 503/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

BATHX BATHWARE INDIA PRIVATE LIMITED,KOCHIN vs. ACIT, CENTRAL IRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 437/COCH/2024[2015-2016]Status: DisposedITAT Cochin20 Dec 2024AY 2015-2016

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