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9 results for “transfer pricing”+ Section 92C(2)clear

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Key Topics

Section 144C(5)13Transfer Pricing7Disallowance6Section 92C5Comparables/TP5Section 92C(3)4Section 92C(2)4Section 404Section 143(3)3Section 144C

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)

2 raised in the present appeal. 4.1. It was contended on behalf of the Assessee that the authorities below did not consider the contentions raised by the Assessee and without appreciating the transfer pricing documentations and the response submitted by the Assessee during the course of assessment proceedings, rejected in the transfer pricing documentation of the Assessee

M/S.US TECHNOLOGY RESOURCES P. LTD,TRIVANDRUM vs. THE ACIT, TRIVANDRUM

3
Natural Justice3
Addition to Income3

In the result, the appeal for assessment year 2011-2012

ITA 134/COCH/2016[2011-12]Status: DisposedITAT Cochin11 May 2018AY 2011-12

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

For Appellant: Sri.Raghunathan S., AdvocateFor Respondent: Sri. Santham Bose, CIT-DR
Section 144C(5)Section 190Section 194JSection 234BSection 40Section 92C(3)

Transfer Pricing) (,TPO'), inter alia, since the TPO has not recorded an opinion that any of the conditions in section 92C(3) of the Act, were satisfied in the instant case. Accordingly, the order passed by the TPO is without jurisdiction.; 2.3. On the facts and in the circumstances of the case and in law, the learned TPO and accordingly

M/S.US TECHNOLOGY RESOURCES P. LTD,TRIVANDRUM vs. THE DCIT, TRIVANDRUM

In the result, the appeal for assessment year 2011-2012

ITA 475/COCH/2016[2012-13]Status: DisposedITAT Cochin11 May 2018AY 2012-13

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

For Appellant: Sri.Raghunathan S., AdvocateFor Respondent: Sri. Santham Bose, CIT-DR
Section 144C(5)Section 190Section 194JSection 234BSection 40Section 92C(3)

Transfer Pricing) (,TPO'), inter alia, since the TPO has not recorded an opinion that any of the conditions in section 92C(3) of the Act, were satisfied in the instant case. Accordingly, the order passed by the TPO is without jurisdiction.; 2.3. On the facts and in the circumstances of the case and in law, the learned TPO and accordingly

US TECHNOLOGY INTERNATIONAL P. LTD,TRIVANDRUM vs. THE ACIT, TRIVANDRUM

In the result, appeal filed by the assessee is partly allowed of statistical purposes

ITA 562/COCH/2022[2017-2018]Status: DisposedITAT Cochin21 Oct 2024AY 2017-2018

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Us Technology International Pvt. Ltd. Acit, Circle - 1(1) 621, Nila, Technopark Campus 1St Floor, Aayakar Bhavan Vs. Kariyavattom, Trivandrum 695581 Kowdiar [Pan: Aaacu5628B] Thiruvananthapuram 695003 (Appellant) (Respondent)

For Appellant: Shri Rajakannan, AdvocateFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 144C(3)Section 92C(3)

Transfer Pricing) ('TPO'), inter alia, since the TPO has not recorded an opinion that any of the conditions in section 92C(3) of the Act, were satisfied in the instant case. Accordingly, the order passed by theTPO is without jurisdiction; 2

THE JT CIT, TRIVANDRUM vs. ALLIANZ CORNHILL INFORMATION SERVICES P. LTD, TRIVANDRUM

In the result, the appeal of the assessee is partly allowed and the

ITA 185/COCH/2015[2010-11]Status: DisposedITAT Cochin20 Dec 2019AY 2010-11

Bench: S/Shri Chandra Poojari, Am & George George K., Jm Assessment Year : 2010-11

Section 10BSection 144C(5)Section 92C(2)

2 Erroneous data used by the TPO • The learned TPO erred in law and on facts in disregarding the application of multiple-year data while computing the margins of alleged comparable companies as such data had an influence in determining the transfer pricing policy of the Assessee. 3 Determination of arm's length price by the TPO in relation

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

In the result, the appeal of the assessee is partly allowed and the

ITA 191/COCH/2015[2010-11]Status: DisposedITAT Cochin20 Dec 2019AY 2010-11

Bench: S/Shri Chandra Poojari, Am & George George K., Jm Assessment Year : 2010-11

Section 10BSection 144C(5)Section 92C(2)

2 Erroneous data used by the TPO • The learned TPO erred in law and on facts in disregarding the application of multiple-year data while computing the margins of alleged comparable companies as such data had an influence in determining the transfer pricing policy of the Assessee. 3 Determination of arm's length price by the TPO in relation

ACIT CORPORATE, COCHIN vs. M/S.JOY ALUKKAS (INDIA) LTD, COCHIN

In the result, the appeal of the assessee is dismissed and the appeal of the

ITA 151/COCH/2015[2010-11]Status: DisposedITAT Cochin09 Apr 2018AY 2010-11

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

Section 143(3)Section 144CSection 144C(5)Section 253Section 36(1)Section 36(1)(iii)Section 92CSection 92C(2)

Transfer Pricing Officer (TPO) to determine the arms length price (ALP). The TPO vide order dated 27/01/2014 passed u/s. 92CA(3) made a recommendation towards TP adjustment of Rs.3,69,19,518/- to the value of international transactions. The Assessing Officer passed draft assessment order on 25/03/2014 proposing other additions also under normal provisions. The assessee filed objections before

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

In the result, the appeal of the assessee is dismissed and the appeal of the

ITA 190/COCH/2015[2010-11]Status: DisposedITAT Cochin09 Apr 2018AY 2010-11

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

Section 143(3)Section 144CSection 144C(5)Section 253Section 36(1)Section 36(1)(iii)Section 92CSection 92C(2)

Transfer Pricing Officer (TPO) to determine the arms length price (ALP). The TPO vide order dated 27/01/2014 passed u/s. 92CA(3) made a recommendation towards TP adjustment of Rs.3,69,19,518/- to the value of international transactions. The Assessing Officer passed draft assessment order on 25/03/2014 proposing other additions also under normal provisions. The assessee filed objections before

UST GLOBAL TECHNOLOGY SERVICES (INDIA) PRIVATE LIMITED,KOCHI vs. DCIT,CORPORATE CIRCLE 2(1), KOCHI

In the result, appeal filed by the assessee stands partly allowed

ITA 1071/COCH/2024[2021-22]Status: DisposedITAT Cochin08 Sept 2025AY 2021-22

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary

For Appellant: Respondent byFor Respondent: Shri Rajakannam, Advocate
Section 143Section 92C

Transfer Pricing Officer (TPO) for the purpose of determination of ALP in respect of the above international transaction. 4 The TPO vide order dated 09/10/2023 passed u/s. 92CA(3), suggested the TP adjustment in respect of software development agreement of Rs. 12,84,50,000/- and also interest on delayed receivables of Rs. 5,97,26,729/- u/s. 92CA