M/S. VIJAYALAXMICASHEW CO.,,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

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

price to sister concerns and, if so, they will be hit hard by Section 40A(2). Hence, it was submitted thatthere was no shifting of profits in favour of sister concerns for their benefit as the transfer

SMT. T.C. USHA,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

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

price to sister concerns and, if so, they will be hit hard by Section 40A(2). Hence, it was submitted thatthere was no shifting of profits in favour of sister concerns for their benefit as the transfer

M/S. VIJAYALAXMICASHEW CO.,,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

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

price to sister concerns and, if so, they will be hit hard by Section 40A(2). Hence, it was submitted thatthere was no shifting of profits in favour of sister concerns for their benefit as the transfer

SRI.R.PRAKASH,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

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

price to sister concerns and, if so, they will be hit hard by Section 40A(2). Hence, it was submitted thatthere was no shifting of profits in favour of sister concerns for their benefit as the transfer

SRI.K.RAVINDRANATHAN NAIR,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

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

price to sister concerns and, if so, they will be hit hard by Section 40A(2). Hence, it was submitted thatthere was no shifting of profits in favour of sister concerns for their benefit as the transfer

M/S. VIJAYALAXMICASHEW CO.,,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

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

price to sister concerns and, if so, they will be hit hard by Section 40A(2). Hence, it was submitted thatthere was no shifting of profits in favour of sister concerns for their benefit as the transfer

SRI.R. PRATAP,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

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

price to sister concerns and, if so, they will be hit hard by Section 40A(2). Hence, it was submitted thatthere was no shifting of profits in favour of sister concerns for their benefit as the transfer

SRI.R. PRATAP,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

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

price to sister concerns and, if so, they will be hit hard by Section 40A(2). Hence, it was submitted thatthere was no shifting of profits in favour of sister concerns for their benefit as the transfer

SRI.R. PRATAP,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

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

price to sister concerns and, if so, they will be hit hard by Section 40A(2). Hence, it was submitted thatthere was no shifting of profits in favour of sister concerns for their benefit as the transfer

SRI.R.PRAKASH,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

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

price to sister concerns and, if so, they will be hit hard by Section 40A(2). Hence, it was submitted thatthere was no shifting of profits in favour of sister concerns for their benefit as the transfer

SRI.R.PRAKASH,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

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

price to sister concerns and, if so, they will be hit hard by Section 40A(2). Hence, it was submitted thatthere was no shifting of profits in favour of sister concerns for their benefit as the transfer

SRI.R.PRAKASH,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

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

price to sister concerns and, if so, they will be hit hard by Section 40A(2). Hence, it was submitted thatthere was no shifting of profits in favour of sister concerns for their benefit as the transfer

SMT. T.C. USHA,KOLLAM vs. THE ACIT, KOLLAM

In the result, the appeals of the assessees in ITA Nos

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

price to sister concerns and, if so, they will be hit hard by Section 40A(2). Hence, it was submitted thatthere was no shifting of profits in favour of sister concerns for their benefit as the transfer

M/S THE REGIONAL AGRO INDUSTRIAL DEVELOPMENT COOPERATIVE OF KERALA LTD,KANNUR vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1, KANNUR RANGE

Bench: The Tribunal Within The Time Prescribed. Accordingly, The Delay Of 69 Days In Filing The Present Appeal Is Condoned.

Section 40A(3) of the Act. The aforesaid disallowance was confirmed by the Learned CIT(A) as the appeal preferred by the Assessee challenging the aforesaid disallowance was dismissed by the Learned CIT(A) vide Order, dated 24/03/2025, impugned by way of present appeal on the grounds reproduced in paragraph 2 above. 4. We have heard both the sides

TORRY HARRIS SEA FOODS LTD,ALAPPUZHA vs. THE ACIT, ALAPPUZHA

In the result, the appeal filed by the assessee is dismissed

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

transfer pricing provisions. You have claimed uniform adjustments @ 3% in all cases, without providing any clear rationale for the same. Adjustments have been claimed in an arbitrary manner without any factual and scientific basis being given. 'You have not submitted the quantification process adopted by you to arrive at the adjustments, claimed. The fact is that 3% adjustment was claimed

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

In the result, ground Nos

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

Transfer pricing adjustment was reduced to Rs.6,72,554. 2.3 The Assessing Officer on receipt of the DRP’s order dated 12.08.2016, passed the final assessment order u/s 143(3) r.w.s. 144C r.w.s. 92CA of the I.T.Act and issued the demand notice u/s 156 of the Act raising a total demand of Rs.9,38,08,666. 2.4 Aggrieved

M/S.MALANKARA ORTHODOX SYRIAN CHURCH MEDICAL MISSION HOSPITAL,COCHIN vs. THE DY DIT (EXEMPTION), COCHIN

In the result, the appeal filed by the assessee is allowed

Bench: S/Shri Abraham P George, Am & George George K, Jm Malankara Orthodox Syrian Church Vs The Dy Director Of Income Tax Medical Mission Hospital (Exemption) Kolencherry 682 311 Kochi ( Appellant) (Respondent)

40A(7) of the I T Act. Therefore, the CIT has rightly disallowed the same in his order passed under section 263 of the I T Act. However, the further question is whether the CIT is right in invoking the provisions of section 11(4) of the Act. To understand this issue, provisions of section

SULAIKHA CLAY MINES,THIRUVANANTHAPURAM vs. ACIT, CIRCLE 1(2), THIRUVANANTHAPURAM, THIRUVANANTHAPURAM

In the result, the appeals for all the years are partly allowed and partly allowed for statistical purposes

Bench: Shri Sanjay Arora & Shri Manomohan Das

transfer from or, as the case may be, to, another working partner – both conspicuous by their absence. The distance of the site from Alappuzha, where only two ladies are said to reside, may be more or less w.r.t. their places of residence for the other three ladies. It is the nature of work, duly exhibited, that would the lead