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72 results for “transfer pricing”+ Section 250clear

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Key Topics

Section 250122Section 220(2)12Section 15412Section 244A12Section 53A6Section 234D6Section 244a6Section 1536Rectification u/s 1546Addition to Income

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)

250 of the Income Tax Act, 1961 (the Act). 2. Heard both the parties. Case file perused. 3. The assessee pleads the following substantive grounds in the instant appeal: 1. The learned Commissioner of Income tax (Appeals)-12, Bengaluru has grossly erred in sustaining the addition in part, for the assessment year 2010-11, on the finding that 2 Sils

Showing 1–20 of 72 · Page 1 of 4

5
Survey u/s 133A5
Capital Gains3

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

250 15 Reimbursement of expenses 1,07,78,001 16 Recovery of expenses 3,69,14,146 3. On noticing the above international transactions, the AO referred the matter to the 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

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

250 lacs, i.e., much lower than its book-value as on 31/3/2014! These interpretations, which are in fact ludicrous, cannot be accepted. VHPL, on purchase, becomes the sole shareholder in Manko, and could always, as it indeed does, transfer sums to Manko either for investment therein, or for paying off it’s liabilities. Nothing, therefore, turns thereon. Why, on take

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

250 lacs, i.e., much lower than its book-value as on 31/3/2014! These interpretations, which are in fact ludicrous, cannot be accepted. VHPL, on purchase, becomes the sole shareholder in Manko, and could always, as it indeed does, transfer sums to Manko either for investment therein, or for paying off it’s liabilities. Nothing, therefore, turns thereon. Why, on take

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

250 of the Act. The learned Commissioner of Income tax (Appeals) has made conclusions in the nature of Ipse Dixit that too without the support of discernible reasons and hence the appellate order stands to be set aside. This view is supported by the decision contained in Sohan Raj Khanted Guvanthraj

RUCHIT PARIMAL ASHAR,SANALA ROAD, MORBI vs. ACIT, CENTRAL CIRLCE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 506/COCH/2024[2019-20]Status: DisposedITAT Cochin20 Dec 2024AY 2019-20

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

250 of the Act. The learned Commissioner of Income tax (Appeals) has made conclusions in the nature of Ipse Dixit that too without the support of discernible reasons and hence the appellate order stands to be set aside. This view is supported by the decision contained in Sohan Raj Khanted Guvanthraj

ABC SALES CORPORATION,KASARAGOD vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 439/COCH/2024[2017-2018]Status: DisposedITAT Cochin20 Dec 2024AY 2017-2018

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

250 of the Act. The learned Commissioner of Income tax (Appeals) has made conclusions in the nature of Ipse Dixit that too without the support of discernible reasons and hence the appellate order stands to be set aside. This view is supported by the decision contained in Sohan Raj Khanted Guvanthraj

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

250 of the Act. The learned Commissioner of Income tax (Appeals) has made conclusions in the nature of Ipse Dixit that too without the support of discernible reasons and hence the appellate order stands to be set aside. This view is supported by the decision contained in Sohan Raj Khanted Guvanthraj

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

250 of the Act. The learned Commissioner of Income tax (Appeals) has made conclusions in the nature of Ipse Dixit that too without the support of discernible reasons and hence the appellate order stands to be set aside. This view is supported by the decision contained in Sohan Raj Khanted Guvanthraj

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

250 of the Act. The learned Commissioner of Income tax (Appeals) has made conclusions in the nature of Ipse Dixit that too without the support of discernible reasons and hence the appellate order stands to be set aside. This view is supported by the decision contained in Sohan Raj Khanted Guvanthraj

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

In the result, appeal of the assessee is hereby dismissed

ITA 436/COCH/2024[2014-2015]Status: DisposedITAT Cochin20 Dec 2024AY 2014-2015

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

250 of the Act. The learned Commissioner of Income tax (Appeals) has made conclusions in the nature of Ipse Dixit that too without the support of discernible reasons and hence the appellate order stands to be set aside. This view is supported by the decision contained in Sohan Raj Khanted Guvanthraj

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

250 of the Act. The learned Commissioner of Income tax (Appeals) has made conclusions in the nature of Ipse Dixit that too without the support of discernible reasons and hence the appellate order stands to be set aside. This view is supported by the decision contained in Sohan Raj Khanted Guvanthraj

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

250 of the Act. The learned Commissioner of Income tax (Appeals) has made conclusions in the nature of Ipse Dixit that too without the support of discernible reasons and hence the appellate order stands to be set aside. This view is supported by the decision contained in Sohan Raj Khanted Guvanthraj

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

250 of the Act. The learned Commissioner of Income tax (Appeals) has made conclusions in the nature of Ipse Dixit that too without the support of discernible reasons and hence the appellate order stands to be set aside. This view is supported by the decision contained in Sohan Raj Khanted Guvanthraj

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

250 of the Act. The learned Commissioner of Income tax (Appeals) has made conclusions in the nature of Ipse Dixit that too without the support of discernible reasons and hence the appellate order stands to be set aside. This view is supported by the decision contained in Sohan Raj Khanted Guvanthraj

ABC SALES CORPORATION,KANNUR vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 458/COCH/2024[2019-2020]Status: DisposedITAT Cochin20 Dec 2024AY 2019-2020

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

250 of the Act. The learned Commissioner of Income tax (Appeals) has made conclusions in the nature of Ipse Dixit that too without the support of discernible reasons and hence the appellate order stands to be set aside. This view is supported by the decision contained in Sohan Raj Khanted Guvanthraj

ABC SALES CORPORATION,KANNUR vs. ACIT, CENTRAL CIRCLE-1, KOZHIKODE

In the result, appeal of the assessee is hereby dismissed

ITA 457/COCH/2024[2019-2020]Status: DisposedITAT Cochin20 Dec 2024AY 2019-2020

Bench: Shri Waseem Ahmed & Shri Soundararajan K

Section 250

250 of the Act. The learned Commissioner of Income tax (Appeals) has made conclusions in the nature of Ipse Dixit that too without the support of discernible reasons and hence the appellate order stands to be set aside. This view is supported by the decision contained in Sohan Raj Khanted Guvanthraj

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

250 of the Act. The learned Commissioner of Income tax (Appeals) has made conclusions in the nature of Ipse Dixit that too without the support of discernible reasons and hence the appellate order stands to be set aside. This view is supported by the decision contained in Sohan Raj Khanted Guvanthraj

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

250 of the Act. The learned Commissioner of Income tax (Appeals) has made conclusions in the nature of Ipse Dixit that too without the support of discernible reasons and hence the appellate order stands to be set aside. This view is supported by the decision contained in Sohan Raj Khanted Guvanthraj

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

250 of the Act. The learned Commissioner of Income tax (Appeals) has made conclusions in the nature of Ipse Dixit that too without the support of discernible reasons and hence the appellate order stands to be set aside. This view is supported by the decision contained in Sohan Raj Khanted Guvanthraj