APPLEXUS TECHNOLOGIES PRIVATE LIMITED,TRIVANDRUM vs. DCIT, KOTTAYAM

Section 144C(5) of the Act for the Assessment Year 2021-2022. 2. The Assessee has raised multiple grounds of appeal which can be grouped as under: Ground No.1: Incorrect rejection of transfer pricing

ASPINWALL & COMPANY LTD,COCHIN vs. THE ACIT, COCHIN

In the result,the appeal of the Revenue in ITA No

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

5. Against this, the assessee is in appeal before us. The Ld. AR submitted that the provisions of sub-section (2) and (3) of section 14A were inserted by the Finance Act, 2006 with effect from April 1, 2007. Hence, it was submitted that the provisions of sub-section (2) and (3) of section 14A of the Act are operative

THE DCIT, COCHIN vs. M/S.ASPINWALL & CO. LTD, COCHIN

In the result,the appeal of the Revenue in ITA No

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

5. Against this, the assessee is in appeal before us. The Ld. AR submitted that the provisions of sub-section (2) and (3) of section 14A were inserted by the Finance Act, 2006 with effect from April 1, 2007. Hence, it was submitted that the provisions of sub-section (2) and (3) of section 14A of the Act are operative

ASPINWALL & COMPANY LTD,COCHIN vs. THE ACIT, COCHIN

In the result,the appeal of the Revenue in ITA No

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

5. Against this, the assessee is in appeal before us. The Ld. AR submitted that the provisions of sub-section (2) and (3) of section 14A were inserted by the Finance Act, 2006 with effect from April 1, 2007. Hence, it was submitted that the provisions of sub-section (2) and (3) of section 14A of the Act are operative

M/S ASPINWALL & CO.,LTD,COCHIN vs. THE ACIT, COCHIN

In the result,the appeal of the Revenue in ITA No

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

5. Against this, the assessee is in appeal before us. The Ld. AR submitted that the provisions of sub-section (2) and (3) of section 14A were inserted by the Finance Act, 2006 with effect from April 1, 2007. Hence, it was submitted that the provisions of sub-section (2) and (3) of section 14A of the Act are operative

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

transfers his goods to another trader at a price less than the market price, and the transaction is a bona fide one, the taxing authority cannot take into account the market price of those goods, ignoring the real price fetched, to ascertain the profit from the transaction.The mere fact that sales were made at prices lower than cost or even

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

transfers his goods to another trader at a price less than the market price, and the transaction is a bona fide one, the taxing authority cannot take into account the market price of those goods, ignoring the real price fetched, to ascertain the profit from the transaction.The mere fact that sales were made at prices lower than cost or even

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

transfers his goods to another trader at a price less than the market price, and the transaction is a bona fide one, the taxing authority cannot take into account the market price of those goods, ignoring the real price fetched, to ascertain the profit from the transaction.The mere fact that sales were made at prices lower than cost or even

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

transfers his goods to another trader at a price less than the market price, and the transaction is a bona fide one, the taxing authority cannot take into account the market price of those goods, ignoring the real price fetched, to ascertain the profit from the transaction.The mere fact that sales were made at prices lower than cost or even

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

transfers his goods to another trader at a price less than the market price, and the transaction is a bona fide one, the taxing authority cannot take into account the market price of those goods, ignoring the real price fetched, to ascertain the profit from the transaction.The mere fact that sales were made at prices lower than cost or even

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

transfers his goods to another trader at a price less than the market price, and the transaction is a bona fide one, the taxing authority cannot take into account the market price of those goods, ignoring the real price fetched, to ascertain the profit from the transaction.The mere fact that sales were made at prices lower than cost or even

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

transfers his goods to another trader at a price less than the market price, and the transaction is a bona fide one, the taxing authority cannot take into account the market price of those goods, ignoring the real price fetched, to ascertain the profit from the transaction.The mere fact that sales were made at prices lower than cost or even

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

transfers his goods to another trader at a price less than the market price, and the transaction is a bona fide one, the taxing authority cannot take into account the market price of those goods, ignoring the real price fetched, to ascertain the profit from the transaction.The mere fact that sales were made at prices lower than cost or even

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

transfers his goods to another trader at a price less than the market price, and the transaction is a bona fide one, the taxing authority cannot take into account the market price of those goods, ignoring the real price fetched, to ascertain the profit from the transaction.The mere fact that sales were made at prices lower than cost or even

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

transfers his goods to another trader at a price less than the market price, and the transaction is a bona fide one, the taxing authority cannot take into account the market price of those goods, ignoring the real price fetched, to ascertain the profit from the transaction.The mere fact that sales were made at prices lower than cost or even

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

transfers his goods to another trader at a price less than the market price, and the transaction is a bona fide one, the taxing authority cannot take into account the market price of those goods, ignoring the real price fetched, to ascertain the profit from the transaction.The mere fact that sales were made at prices lower than cost or even

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

transfers his goods to another trader at a price less than the market price, and the transaction is a bona fide one, the taxing authority cannot take into account the market price of those goods, ignoring the real price fetched, to ascertain the profit from the transaction.The mere fact that sales were made at prices lower than cost or even

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

transfers his goods to another trader at a price less than the market price, and the transaction is a bona fide one, the taxing authority cannot take into account the market price of those goods, ignoring the real price fetched, to ascertain the profit from the transaction.The mere fact that sales were made at prices lower than cost or even

M/S.IBS SOFTWARE SERVICES P. LTD,TRIVANDRUM vs. THE DCIT, TRIVANDRUM

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

2. That the directions of the learned Panel and the consequent assessment order is bad in law and on facts while upholding the action of the learned Additional Commissioner of Income- tax, (Transfer Pricing). Kochi (learned Transfer Pricing Officer' or 'learned TPO) of making an adjustment of INR 310,952.334 to the transfer price of the Appellant's international transaction