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70 results for “transfer pricing”+ Section 43(6)clear

Sorted by relevance

Mumbai1,111Delhi1,034Chennai224Hyderabad222Bangalore216Ahmedabad186Jaipur152Chandigarh133Kolkata91Indore73Cochin70Rajkot54Surat51Pune39Nagpur36Raipur31Visakhapatnam23Cuttack21Guwahati20Jodhpur19Agra17Amritsar15Lucknow12Varanasi6Allahabad3Dehradun2Panaji2Patna1

Key Topics

Section 250114Section 143(3)12Addition to Income9Section 92C5Section 1474Section 133A4Survey u/s 133A4Section 12A3Section 113

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

6. The appellant-company also submitted the TP study report adopting the internal TNMM as most appropriate method and sought to justify the above international transactions are at arm’s length price (ALP). On noticing the above, the AO referred the matter to 3 IT (TP) A No. 119/Coch/2016 & IT (TP) A Nos. 38 & 643/Coch/2017 M/s. Joyalukkas India

Showing 1–20 of 70 · Page 1 of 4

Section 2(15)3
Charitable Trust3
Exemption3

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

6. The appellant-company also submitted the TP study report adopting the internal TNMM as most appropriate method and sought to justify the above international transactions are at arm’s length price (ALP). On noticing the above, the AO referred the matter to 3 IT (TP) A No. 119/Coch/2016 & IT (TP) A Nos. 38 & 643/Coch/2017 M/s. Joyalukkas India

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

43,689 Dt. 18/02/2014 Total: Rs 6,75,00,000/-” (emphasis, supplied) The primary facts are undisputed, and for which, apart from the sale agreement, we may refer to the Manko’s reply dated 05.12.2016, reproduced at page 12 of the assessment order, reproducing it in its relevant part, as under: “With reference to the above we are herewith producing

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

43,689 Dt. 18/02/2014 Total: Rs 6,75,00,000/-” (emphasis, supplied) The primary facts are undisputed, and for which, apart from the sale agreement, we may refer to the Manko’s reply dated 05.12.2016, reproduced at page 12 of the assessment order, reproducing it in its relevant part, as under: “With reference to the above we are herewith producing

GOOD HOMES PVT LTD,KOCHI vs. DEPUTY COMMISSIONER OF INCOME TAX CORPORATE CIRCLE 1(1), KOCHI

In the result, the assessee’s appeals are allowed for statistical purposes

ITA 884/COCH/2022[2007-08]Status: DisposedITAT Cochin11 Aug 2023AY 2007-08

Bench: Shri Sanjay Arora, Am &Shriabyt.Varkey, Jm

For Appellant: Sri.A.Gopalakrishnan, CAFor Respondent: Smt.J.M.Jamuna Devi, Sr.AR
Section 133ASection 147Section 148

section 147 r.w.s. 143(3) of the Income-tax Act, 1961 (hereinafter ‘the Act’) dated 18.3.2015 and 29.3.2014 for assessment year (AY) 2007-2008, respectively. The background facts of both the cases being same, these are heard together, and are being disposed of pera common, consolidated order for the sake of convenience. ITA Nos.870& 884 /Coch/2022 (AY 2007-08) Ajit

AJIT ASSOCIATES PRIVATE LIMITED,ERNAKULAM vs. JCIT, CORPORATE RANGE - 1, KOCHI

In the result, the assessee’s appeals are allowed for statistical purposes

ITA 870/COCH/2022[2007-08]Status: DisposedITAT Cochin11 Aug 2023AY 2007-08

Bench: Shri Sanjay Arora, Am &Shriabyt.Varkey, Jm

For Appellant: Sri.A.Gopalakrishnan, CAFor Respondent: Smt.J.M.Jamuna Devi, Sr.AR
Section 133ASection 147Section 148

section 147 r.w.s. 143(3) of the Income-tax Act, 1961 (hereinafter ‘the Act’) dated 18.3.2015 and 29.3.2014 for assessment year (AY) 2007-2008, respectively. The background facts of both the cases being same, these are heard together, and are being disposed of pera common, consolidated order for the sake of convenience. ITA Nos.870& 884 /Coch/2022 (AY 2007-08) Ajit

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

6. The Tribunal in the impugned order has concurred with the findings recorded by the Commissioner (Appeals) and has observed that the revenue has not disputed the fact that there is no discrepancy with regard to quantitative details of the stock items and that the only difference is with regard to adopting the value of closing stock. The Tribunal placed

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

6. The Tribunal in the impugned order has concurred with the findings recorded by the Commissioner (Appeals) and has observed that the revenue has not disputed the fact that there is no discrepancy with regard to quantitative details of the stock items and that the only difference is with regard to adopting the value of closing stock. The Tribunal placed

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

6. The Tribunal in the impugned order has concurred with the findings recorded by the Commissioner (Appeals) and has observed that the revenue has not disputed the fact that there is no discrepancy with regard to quantitative details of the stock items and that the only difference is with regard to adopting the value of closing stock. The Tribunal placed

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

6. The Tribunal in the impugned order has concurred with the findings recorded by the Commissioner (Appeals) and has observed that the revenue has not disputed the fact that there is no discrepancy with regard to quantitative details of the stock items and that the only difference is with regard to adopting the value of closing stock. The Tribunal placed

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

6. The Tribunal in the impugned order has concurred with the findings recorded by the Commissioner (Appeals) and has observed that the revenue has not disputed the fact that there is no discrepancy with regard to quantitative details of the stock items and that the only difference is with regard to adopting the value of closing stock. The Tribunal placed

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

6. The Tribunal in the impugned order has concurred with the findings recorded by the Commissioner (Appeals) and has observed that the revenue has not disputed the fact that there is no discrepancy with regard to quantitative details of the stock items and that the only difference is with regard to adopting the value of closing stock. The Tribunal placed

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

6. The Tribunal in the impugned order has concurred with the findings recorded by the Commissioner (Appeals) and has observed that the revenue has not disputed the fact that there is no discrepancy with regard to quantitative details of the stock items and that the only difference is with regard to adopting the value of closing stock. The Tribunal placed

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

6. The Tribunal in the impugned order has concurred with the findings recorded by the Commissioner (Appeals) and has observed that the revenue has not disputed the fact that there is no discrepancy with regard to quantitative details of the stock items and that the only difference is with regard to adopting the value of closing stock. The Tribunal placed

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

6. The Tribunal in the impugned order has concurred with the findings recorded by the Commissioner (Appeals) and has observed that the revenue has not disputed the fact that there is no discrepancy with regard to quantitative details of the stock items and that the only difference is with regard to adopting the value of closing stock. The Tribunal placed

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

6. The Tribunal in the impugned order has concurred with the findings recorded by the Commissioner (Appeals) and has observed that the revenue has not disputed the fact that there is no discrepancy with regard to quantitative details of the stock items and that the only difference is with regard to adopting the value of closing stock. The Tribunal placed

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

6. The Tribunal in the impugned order has concurred with the findings recorded by the Commissioner (Appeals) and has observed that the revenue has not disputed the fact that there is no discrepancy with regard to quantitative details of the stock items and that the only difference is with regard to adopting the value of closing stock. The Tribunal placed

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

6. The Tribunal in the impugned order has concurred with the findings recorded by the Commissioner (Appeals) and has observed that the revenue has not disputed the fact that there is no discrepancy with regard to quantitative details of the stock items and that the only difference is with regard to adopting the value of closing stock. The Tribunal placed

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

6. The Tribunal in the impugned order has concurred with the findings recorded by the Commissioner (Appeals) and has observed that the revenue has not disputed the fact that there is no discrepancy with regard to quantitative details of the stock items and that the only difference is with regard to adopting the value of closing stock. The Tribunal placed