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75 results for “transfer pricing”+ Section 49(1)clear

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Key Topics

Section 250115Section 143(3)21Section 80G12Addition to Income10Section 153C7Section 1326Section 53A6Section 80H5Section 153A5

APPLEXUS TECHNOLOGIES PRIVATE LIMITED,TRIVANDRUM vs. DCIT, KOTTAYAM

ITA 955/COCH/2024[2021-2022]Status: DisposedITAT Cochin13 Nov 2025AY 2021-2022
For Appellant: Shri Reuben JosephFor Respondent: Shri Sanjit Kumar Das
Section 143(3)Section 144BSection 144CSection 144C(1)Section 144C(5)

1 crore and >50 crores are not appropriate filters for a service industry according to the TPO. Further, use of filters such as non-availability of financial data pertaining to any financial year under review ie., FY 2018-19, FY 2019-20 and FY 2020-21 is inappropriate. Use of such filter may have led to rejection of some good

M/S.APOLLO TYRES LTD,COCHIN vs. THE PRINCIPAL COMMISSIONER OF INCOMETAX, COCHIN

Showing 1–20 of 75 · Page 1 of 4

Charitable Trust3
Exemption3
Limitation/Time-bar3

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

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)

1, 2010. Explanatory Notes Explaining the Provisions of Finance Bill reads as under*: "Taxation of certain transactions without consideration or for inadequate consideration. Under the existing provisions of section 56(2)(vii), any sum of money or any property in kind which is received without 7 Sils Karingattil Jose consideration or for inadequate consideration (in excess of the prescribed limit

SHRI.PRAKASH R. NAIR,KOLLAM vs. DCIT, KOLLAM

In the result, the assessee’s appeal is partly allowed for statistical purposes

ITA 141/COCH/2021[2000-2001]Status: DisposedITAT Cochin17 Jan 2024AY 2000-2001

Bench: Shri Sanjay Arora & Shri Manomohan Dasprakash R. Nair Dy.Cit, Central Circle Prop. Dhanya Foods Kollam Kochuppilammoodu Vs. Kollam 691001 [Pan:Abfpn4424P] (Appellant) (Respondent)

For Appellant: Shri R. Vijayaraghavan, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 143(1)Section 148(1)Section 271(1)(c)Section 274Section 80Section 801A(9)Section 80HSection 80I

transferring profit to the sister concern/s, which charge is though, both unproved and incidental, on which nothing therefore turns, even as explained in Patel Chemical Works (supra). We may though add that the assessee’s reply should also meet the other incident observations by the AO in the assessment order, noted by us at para 2 (pg. 3) of this

PLANT LIPIDS (P) LTD.,KADAYIRUPPU vs. DCIT , CORPORATE CIRCLE-2(1), KOCHI

In the result appeal filed by assessee stands allowed

ITA 598/COCH/2024[2020-21]Status: DisposedITAT Cochin19 May 2025AY 2020-21

Bench: Shri Inturi Rama Rao & Shri Keshav Dubeyassessmentyear:2020-21 Plant Lipids (P) Ltd. Kadayiruppu Po Kolenchery Dcit, Vs. Kerala 682 311 Corporate Circle-2(1) Kochi Pan No : Aabcp6061C Appellant Respondent Appellant By : Shri Thomson Thomas, A.R. Respondent By : Shri Sanjit Kumar Das, D.R. Date Of Hearing : 20.02.2025 Date Of Pronouncement : 19.05.2025 O R D E R Perkeshav Dubey: This Appeal At The Instance Of The Assessee Is Directed Against The Order Of The Ao, Assessment Unit, Income Tax Department Dated 19.6.2024 Vide Din No.Itba/Ast/S/143(3)/2024- 25/1065876641(1) For The Ay 2020-21 Passed U/S 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income Tax Act, 1961 (In Short “The Act”). 2. The Assessee Has Raised Following Grounds Of Appeal: Plant Lipids (P) Ltd., Kolencherry, Kerala Page 2 Of 8

For Appellant: Shri Thomson Thomas, A.RFor Respondent: Shri Sanjit Kumar Das, D.R
Section 143(3)Section 144(1)Section 144CSection 80GSection 92C

Transfer Pricing Order made an adjustment of Rs.2,03,38,752/- towards notional guarantee commission in respect of corporate guarantee given by the assessee for its Subsidiary.After receiving the order of the TPO, the Assessing Officer made a draft assessment order u/s 144(1) proposing to make the following adjustments:- i. Addition as proposed by TPO — towards notional Guarantee Commission

SRI.JOSE THOMAS,ADOOR P.O., PATHANAMTHITTA vs. THE ACIT,CEN-CIRCLE, KOTTAYAM

In the result, all the appeals filed by the assessee are dismissed

ITA 212/COCH/2019[2010-11]Status: DisposedITAT Cochin22 May 2025AY 2010-11

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadav

For Appellant: Sri.Anil D.Nair, AdvocateFor Respondent: Sri.Sundarasan S, CIT-DR
Section 132Section 143(3)Section 153ASection 153C

transfer cannot be treated as 'income from capital gain'. The CIT(A) treated it as "income from other sources" so as to tax the same. This finding of the CIT(A) is not proper. The assesses herein were holding trusteeship in the Carmel Educational Trust which was relinquished in favour of trustees of Believers Church, and this right is nothing

MRS.GRACY BABU,ADOOR P.O., PATHANAMTHITTA vs. THE DCIT, CEN-CIRCLE, KOTTAYAM

In the result, all the appeals filed by the assessee are dismissed

ITA 209/COCH/2019[2010-11]Status: DisposedITAT Cochin22 May 2025AY 2010-11

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadav

For Appellant: Sri.Anil D.Nair, AdvocateFor Respondent: Sri.Sundarasan S, CIT-DR
Section 132Section 143(3)Section 153ASection 153C

transfer cannot be treated as 'income from capital gain'. The CIT(A) treated it as "income from other sources" so as to tax the same. This finding of the CIT(A) is not proper. The assesses herein were holding trusteeship in the Carmel Educational Trust which was relinquished in favour of trustees of Believers Church, and this right is nothing

MRS.REENA JOSE,PATHANAMTHITTA vs. THE DCIT, CEN-CIRCLE,, KOTTAYAM

In the result, all the appeals filed by the assessee are dismissed

ITA 207/COCH/2019[2009-10]Status: DisposedITAT Cochin22 May 2025AY 2009-10

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadav

For Appellant: Sri.Anil D.Nair, AdvocateFor Respondent: Sri.Sundarasan S, CIT-DR
Section 132Section 143(3)Section 153ASection 153C

transfer cannot be treated as 'income from capital gain'. The CIT(A) treated it as "income from other sources" so as to tax the same. This finding of the CIT(A) is not proper. The assesses herein were holding trusteeship in the Carmel Educational Trust which was relinquished in favour of trustees of Believers Church, and this right is nothing

SRI.JOSE THOMAS,ADOOR P.O., PATHANAMTHITTA vs. THE ACIT,CEN-CIRCLE, KOTTAYAM

In the result, all the appeals filed by the assessee are dismissed

ITA 211/COCH/2019[2009-10]Status: DisposedITAT Cochin22 May 2025AY 2009-10

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadav

For Appellant: Sri.Anil D.Nair, AdvocateFor Respondent: Sri.Sundarasan S, CIT-DR
Section 132Section 143(3)Section 153ASection 153C

transfer cannot be treated as 'income from capital gain'. The CIT(A) treated it as "income from other sources" so as to tax the same. This finding of the CIT(A) is not proper. The assesses herein were holding trusteeship in the Carmel Educational Trust which was relinquished in favour of trustees of Believers Church, and this right is nothing

MRS.GRACY BABU,ADOOR P.O., PATHANAMTHITTA vs. THE DCIT, CEN-CIRCLE, KOTTAYAM

In the result, all the appeals filed by the assessee are dismissed

ITA 208/COCH/2019[2009-10]Status: DisposedITAT Cochin22 May 2025AY 2009-10

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadav

For Appellant: Sri.Anil D.Nair, AdvocateFor Respondent: Sri.Sundarasan S, CIT-DR
Section 132Section 143(3)Section 153ASection 153C

transfer cannot be treated as 'income from capital gain'. The CIT(A) treated it as "income from other sources" so as to tax the same. This finding of the CIT(A) is not proper. The assesses herein were holding trusteeship in the Carmel Educational Trust which was relinquished in favour of trustees of Believers Church, and this right is nothing

THE DCIT,CEN-CIRCLE,, THRISSUR vs. SRI.T.G. CHANDRAKUMAR, THRISSUR

In the result, the Appeal by the Revenue is allowed on the aforesaid terms

ITA 67/COCH/2018[2008-09]Status: DisposedITAT Cochin03 Apr 2023AY 2008-09

Bench: Shri Sanjay Arora (Accountant Member), Shri Sandeep Gosain (Judicial Member)

For Appellant: Smt. J.M. Jamuna Devi, Sr. DRFor Respondent: Shri C.B.M. Warrier, FCA
Section 132Section 153CSection 268A

section (3) thereof, would have no bearing on the merits of the case. The decision by the first appellate authority for that year, as for the current year, cannot bind this Tribunal, so that the matter cannot be regarded as covered, and would require being adjudicated by it on merits. The same would though be relevant and taken into account

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

49. The last issue raised by the assessee vide ground No. 13 of its appeal is that the learned CIT(A) erred in confirming the addition of Rs. 9,22,75,684/- on account of excess stock. 50. During the search proceedings conducted on 27-02-2020 at the showroom of the assessee, namely ABC Emporio in Kannur

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

49. The last issue raised by the assessee vide ground No. 13 of its appeal is that the learned CIT(A) erred in confirming the addition of Rs. 9,22,75,684/- on account of excess stock. 50. During the search proceedings conducted on 27-02-2020 at the showroom of the assessee, namely ABC Emporio in Kannur

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

49. The last issue raised by the assessee vide ground No. 13 of its appeal is that the learned CIT(A) erred in confirming the addition of Rs. 9,22,75,684/- on account of excess stock. 50. During the search proceedings conducted on 27-02-2020 at the showroom of the assessee, namely ABC Emporio in Kannur

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

49. The last issue raised by the assessee vide ground No. 13 of its appeal is that the learned CIT(A) erred in confirming the addition of Rs. 9,22,75,684/- on account of excess stock. 50. During the search proceedings conducted on 27-02-2020 at the showroom of the assessee, namely ABC Emporio in Kannur

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

49. The last issue raised by the assessee vide ground No. 13 of its appeal is that the learned CIT(A) erred in confirming the addition of Rs. 9,22,75,684/- on account of excess stock. 50. During the search proceedings conducted on 27-02-2020 at the showroom of the assessee, namely ABC Emporio in Kannur

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

49. The last issue raised by the assessee vide ground No. 13 of its appeal is that the learned CIT(A) erred in confirming the addition of Rs. 9,22,75,684/- on account of excess stock. 50. During the search proceedings conducted on 27-02-2020 at the showroom of the assessee, namely ABC Emporio in Kannur

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

49. The last issue raised by the assessee vide ground No. 13 of its appeal is that the learned CIT(A) erred in confirming the addition of Rs. 9,22,75,684/- on account of excess stock. 50. During the search proceedings conducted on 27-02-2020 at the showroom of the assessee, namely ABC Emporio in Kannur

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

49. The last issue raised by the assessee vide ground No. 13 of its appeal is that the learned CIT(A) erred in confirming the addition of Rs. 9,22,75,684/- on account of excess stock. 50. During the search proceedings conducted on 27-02-2020 at the showroom of the assessee, namely ABC Emporio in Kannur

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

49. The last issue raised by the assessee vide ground No. 13 of its appeal is that the learned CIT(A) erred in confirming the addition of Rs. 9,22,75,684/- on account of excess stock. 50. During the search proceedings conducted on 27-02-2020 at the showroom of the assessee, namely ABC Emporio in Kannur