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87 results for “transfer pricing”+ Section 254clear

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Key Topics

Section 250114Addition to Income22Section 153A17Section 13213Exemption13Section 143(3)11Section 14A8Disallowance7Section 133A6

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

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

Showing 1–20 of 87 · Page 1 of 5

Section 43B5
Section 50B4
Transfer Pricing3

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.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

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 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

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

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

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

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

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.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

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

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.MICROOBJECTS P. LTD,COCHIN vs. THE ACIT, COCHIN

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

ITA 470/COCH/2016[2012-13]Status: DisposedITAT Cochin05 Oct 2017AY 2012-13

Bench: S/Shri P K Bansal & George George K, Jm M/S. Microobjects Private Limited, Vs The Asst. Commr Of Income Tax 41/1098B, Pullepady Cross Road, Corporate Circle 1(2), Kochi. Kochi-682018. ( Appellant) (Respondent)

Section 1Section 143(3)Section 144CSection 144C(2)(b)Section 144C(4)Section 144C(5)Section 92C

section 144C of the I.T. Act. The relevant assessment year is 2012-13. 2. Briefly stated the facts of the case are as follows: The assessee is a private limited company. It is a captive service provider (software developer) for its associate enterprise (AE) which is based in USA. For the assessment year 2011-12, the return of income

THE ACIT, CORP CIRCLE-1(1), KOCHI, ERNAKULAM vs. APPOLO TYRES LTD, ERNAKULAM

In the result, the appeal filed by the Revenue in ITA No

ITA 247/COCH/2018[2006-07]Status: DisposedITAT Cochin21 Mar 2019AY 2006-07

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

Section 143(3)Section 80I

Transfer Pricing adjustment @ 0.6% as claimed by the assessee and to remove the three companies out of five companies arrived by the TPO, which are broadly engaged in similar services and therefore functionally comparable. 5. In the facts and circumstances of the case, the learned Commissioner of Income Tax (Appeals) erred in allowing deduction u/s. 80IA on gas turbine unit

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

254 only to decide the grounds which arise from the order of the Commissioner of Income-tax (Appeals). Both the assessee as well as the Department have a right to file an appeal/cross-objections before the Tribunal. The Tribunal should not be prevented from considering questions of law arising in assessment proceedings, although not raised earlier. . ITA No.404 & others/Coch/2024 Page

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

254 only to decide the grounds which arise from the order of the Commissioner of Income-tax (Appeals). Both the assessee as well as the Department have a right to file an appeal/cross-objections before the Tribunal. The Tribunal should not be prevented from considering questions of law arising in assessment proceedings, although not raised earlier. . ITA No.404 & others/Coch/2024 Page

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

254 only to decide the grounds which arise from the order of the Commissioner of Income-tax (Appeals). Both the assessee as well as the Department have a right to file an appeal/cross-objections before the Tribunal. The Tribunal should not be prevented from considering questions of law arising in assessment proceedings, although not raised earlier. . ITA No.404 & others/Coch/2024 Page