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105 results for “transfer pricing”+ Section 43(5)clear

Sorted by relevance

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Key Topics

Section 250104Addition to Income34Section 143(3)25Section 26319Section 153A17Exemption16Disallowance14Section 13213Section 133A10

THE ACIT, COCHIN vs. M/S.SUD CHEMIE INDIA P. LTD, COCHIN

In the result, the appeals of the Revenue are partly allowed for statistical

ITA 41/COCH/2017[2010-11]Status: DisposedITAT Cochin26 Feb 2018AY 2010-11

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

43(5) of the Act, gives a simple test for deciding for the purpose of income-tax what a speculative transaction I.T.A. Nos./ 3, 17 & 41/C/2017 means. If a contract for sale or purchase is ultimately settled and no actual delivery of the goods was effected under the settlement then it is a speculative transaction. The requirement of section

THE ACIT, COCHIN vs. M/S.SUD CHEMIE INDIA P. LTD, ALUVA

In the result, the appeals of the Revenue are partly allowed for statistical

ITA 3/COCH/2017[2008-09]Status: DisposedITAT Cochin26 Feb 2018AY 2008-09

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

43(5) of the Act, gives a simple test for deciding for the purpose of income-tax what a speculative transaction I.T.A. Nos./ 3, 17 & 41/C/2017 means. If a contract for sale or purchase is ultimately settled and no actual delivery of the goods was effected under the settlement then it is a speculative transaction. The requirement of section

Showing 1–20 of 105 · Page 1 of 6

Section 14A8
Survey u/s 133A8
Section 144C(5)6

M/S.JOY ALUKKAS INDIA P. LTD,TRICHUR vs. THE ACIT, ERNAKULAM

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

ITA 119/COCH/2016[2011-12]Status: DisposedITAT Cochin08 Sept 2025AY 2011-12

Bench: Shri Inturi Rama Rao, Am& Shri Rahul Chaudharyit (Tp) A No. 119/Coch/2016 (Assessment Year: 2011-12) & It (Tp) A Nos. 38 & 643/Coch/2017 (Assessment Years :2012-13 & 2013-14)

For Appellant: Smt. Parvathy Ammal, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)Section 36(1)(iii)Section 36(1)(viii)Section 92C

43,154/-. The TPO also suggested the TP adjustment of Rs. 1,54,18,632/- on account of expenses towards fee for brand utilization expenditure by adopting the Bright Line test method vide order dated 30/01/2015 passed u/s. 92CA (3) of the Act. 7. The AO on receipt of the TPO’s order passed draft assessment order on 27/12/2016

M/S.JOY ALUKKAS INDIA P. LTD,COCHIN vs. THE ACIT, COCHIN

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

ITA 38/COCH/2017[2012-13]Status: DisposedITAT Cochin08 Sept 2025AY 2012-13

Bench: Shri Inturi Rama Rao, Am& Shri Rahul Chaudharyit (Tp) A No. 119/Coch/2016 (Assessment Year: 2011-12) & It (Tp) A Nos. 38 & 643/Coch/2017 (Assessment Years :2012-13 & 2013-14)

For Appellant: Smt. Parvathy Ammal, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)Section 36(1)(iii)Section 36(1)(viii)Section 92C

43,154/-. The TPO also suggested the TP adjustment of Rs. 1,54,18,632/- on account of expenses towards fee for brand utilization expenditure by adopting the Bright Line test method vide order dated 30/01/2015 passed u/s. 92CA (3) of the Act. 7. The AO on receipt of the TPO’s order passed draft assessment order on 27/12/2016

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

section 80HHC of the Act, has not been explained. 4.1 Before the CIT(A), the assessee argued that assessee’s selling price has nothing to do with cost of production since sales made to sister concerns consisted of a mix of higher grades and inferior grades. The CIT(A) observed that while the higher grades realized above cost, the inferior

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

section 80HHC of the Act, has not been explained. 4.1 Before the CIT(A), the assessee argued that assessee’s selling price has nothing to do with cost of production since sales made to sister concerns consisted of a mix of higher grades and inferior grades. The CIT(A) observed that while the higher grades realized above cost, the inferior

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

section 80HHC of the Act, has not been explained. 4.1 Before the CIT(A), the assessee argued that assessee’s selling price has nothing to do with cost of production since sales made to sister concerns consisted of a mix of higher grades and inferior grades. The CIT(A) observed that while the higher grades realized above cost, the inferior

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

section 80HHC of the Act, has not been explained. 4.1 Before the CIT(A), the assessee argued that assessee’s selling price has nothing to do with cost of production since sales made to sister concerns consisted of a mix of higher grades and inferior grades. The CIT(A) observed that while the higher grades realized above cost, the inferior

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

section 80HHC of the Act, has not been explained. 4.1 Before the CIT(A), the assessee argued that assessee’s selling price has nothing to do with cost of production since sales made to sister concerns consisted of a mix of higher grades and inferior grades. The CIT(A) observed that while the higher grades realized above cost, the inferior

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

section 80HHC of the Act, has not been explained. 4.1 Before the CIT(A), the assessee argued that assessee’s selling price has nothing to do with cost of production since sales made to sister concerns consisted of a mix of higher grades and inferior grades. The CIT(A) observed that while the higher grades realized above cost, the inferior

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

section 80HHC of the Act, has not been explained. 4.1 Before the CIT(A), the assessee argued that assessee’s selling price has nothing to do with cost of production since sales made to sister concerns consisted of a mix of higher grades and inferior grades. The CIT(A) observed that while the higher grades realized above cost, the inferior

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

section 80HHC of the Act, has not been explained. 4.1 Before the CIT(A), the assessee argued that assessee’s selling price has nothing to do with cost of production since sales made to sister concerns consisted of a mix of higher grades and inferior grades. The CIT(A) observed that while the higher grades realized above cost, the inferior

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

section 80HHC of the Act, has not been explained. 4.1 Before the CIT(A), the assessee argued that assessee’s selling price has nothing to do with cost of production since sales made to sister concerns consisted of a mix of higher grades and inferior grades. The CIT(A) observed that while the higher grades realized above cost, the inferior

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

section 80HHC of the Act, has not been explained. 4.1 Before the CIT(A), the assessee argued that assessee’s selling price has nothing to do with cost of production since sales made to sister concerns consisted of a mix of higher grades and inferior grades. The CIT(A) observed that while the higher grades realized above cost, the inferior

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

section 80HHC of the Act, has not been explained. 4.1 Before the CIT(A), the assessee argued that assessee’s selling price has nothing to do with cost of production since sales made to sister concerns consisted of a mix of higher grades and inferior grades. The CIT(A) observed that while the higher grades realized above cost, the inferior

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

section 80HHC of the Act, has not been explained. 4.1 Before the CIT(A), the assessee argued that assessee’s selling price has nothing to do with cost of production since sales made to sister concerns consisted of a mix of higher grades and inferior grades. The CIT(A) observed that while the higher grades realized above cost, the inferior

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

section 80HHC of the Act, has not been explained. 4.1 Before the CIT(A), the assessee argued that assessee’s selling price has nothing to do with cost of production since sales made to sister concerns consisted of a mix of higher grades and inferior grades. The CIT(A) observed that while the higher grades realized above cost, the inferior

THARIF BUILDERS P. LTD,KOZHIKKODE vs. THEACIT, KOZHIKKODE

In the result, the appeals of the assessee are partly allowed

ITA 488/COCH/2019[2015-16]Status: DisposedITAT Cochin19 May 2020AY 2015-16

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

Section 132Section 133ASection 143(3)Section 153A

43,520/-. The CIT(A) has gone wrong in arriving at the net surplus without considering the construction expenses of Rs.16,11,88,680/- spent by the appellant up to 31- 03-2016 (relating to assessment year 2016-17). 4. The assessee has also raised common additional ground of appeals as follows: Whether the AO is justified in making assessment

THARIF BUILDERS P. LTD,KOZHIKKODE vs. THEACIT, KOZHIKKODE

In the result, the appeals of the assessee are partly allowed

ITA 487/COCH/2019[2014-15]Status: DisposedITAT Cochin19 May 2020AY 2014-15

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

Section 132Section 133ASection 143(3)Section 153A

43,520/-. The CIT(A) has gone wrong in arriving at the net surplus without considering the construction expenses of Rs.16,11,88,680/- spent by the appellant up to 31- 03-2016 (relating to assessment year 2016-17). 4. The assessee has also raised common additional ground of appeals as follows: Whether the AO is justified in making assessment

THARIF BUILDERS P. LTD,KOZHIKKODE vs. THEACIT, KOZHIKKODE

In the result, the appeals of the assessee are partly allowed

ITA 489/COCH/2019[2016-17]Status: DisposedITAT Cochin19 May 2020AY 2016-17

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

Section 132Section 133ASection 143(3)Section 153A

43,520/-. The CIT(A) has gone wrong in arriving at the net surplus without considering the construction expenses of Rs.16,11,88,680/- spent by the appellant up to 31- 03-2016 (relating to assessment year 2016-17). 4. The assessee has also raised common additional ground of appeals as follows: Whether the AO is justified in making assessment