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39 results for “transfer pricing”

Sorted by relevance

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Key Topics

Section 801A63Addition to Income34Section 10(38)24Section 26312Section 26012Deduction12Exemption12Section 14710Section 119

KSSIIPL VEL JV,PURI vs. ACIT CIRCLE-5(1), BHUBANESWAR

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

ITA 91/CTK/2023[2014-15]Status: DisposedITAT Cuttack29 Aug 2024AY 2014-15
For Appellant: Ms. Pooja Dhalwani, CAFor Respondent: Shri Sanjay Kumar, CIT-DR
Section 143(2)Section 40A(2)Section 92C

price in respect of the specified domestic transactions. The Transfer Pricing Authority re-computed the arm's length price of the payment

INDIAN METALS AND FERRO ALLOYS LTD,BHUBANESWAR vs. DCIT, CIRCLE-1(1), BHUBANESWAR

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

Showing 1–20 of 39 · Page 1 of 2

Section 143(3)8
Section 269S8
Disallowance7
ITA 506/CTK/2024[2021-22]Status: Disposed
ITAT Cuttack
19 Aug 2025
AY 2021-22

Bench: Shri Duvvuru Rl Reddy(Kz) & Shri Rakesh Mishra

Section 143(1)Section 143(2)Section 143(3)Section 144C(5)Section 234BSection 234CSection 270ASection 92CSection 92D

price charged for property or services transferred in a controlled transaction to the price charged for property or services transferred

PARADIP PORT AUTHORITY,JAGATSINGHPUR vs. DCIT,CIRCLE-1(1), CUTTACK

In the result, all the three appeals of the assessee are allowed

ITA 209/CTK/2024[2004-05]Status: DisposedITAT Cuttack25 Sept 2024AY 2004-05
Section 11Section 11(1)(a)Section 12ASection 260Section 263

Transfer Pricing Officer, as the case may be,] is erroneous in so far as it is prejudicial to the interests

PARADIP PORT AUTHORITY,JAGATSINGHPUR vs. DCIT,CIRCLE-1(1), CUTTACK

In the result, all the three appeals of the assessee are allowed

ITA 208/CTK/2024[2003-04]Status: DisposedITAT Cuttack25 Sept 2024AY 2003-04
Section 11Section 11(1)(a)Section 12ASection 260Section 263

Transfer Pricing Officer, as the case may be,] is erroneous in so far as it is prejudicial to the interests

PARADIP PORT AUTHORITY,JAGATSINGHPUR vs. DCIT,CIRCLE1(1), CUTTACK

In the result, all the three appeals of the assessee are allowed

ITA 210/CTK/2024[2005-06]Status: DisposedITAT Cuttack25 Sept 2024AY 2005-06
Section 11Section 11(1)(a)Section 12ASection 260Section 263

Transfer Pricing Officer, as the case may be,] is erroneous in so far as it is prejudicial to the interests

ITO, ANGUL WARD, , ANGUL vs. M/S. NCC SMASL JRT(JV),, ANGUL

ITA 99/CTK/2019[2014-15]Status: DisposedITAT Cuttack25 Jul 2024AY 2014-15
For Appellant: Shri Salil Kapoor and Bibhu Jain, AdvsFor Respondent: Shri Sanjay Kumar, CIT-DR
Section 40A(2)(b)

price, which is determined appropriately. 2. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) is not justified in deleting the above addition holding that the entire sale proceeds has been transferred

ITO, ANGUL WARD, ANGUL vs. NCC-SMASL-JRT(JV), ANGUL

ITA 39/CTK/2018[2013-14]Status: HeardITAT Cuttack25 Jul 2024AY 2013-14
For Appellant: Shri Salil Kapoor and Bibhu Jain, AdvsFor Respondent: Shri Sanjay Kumar, CIT-DR
Section 40A(2)(b)

price, which is determined appropriately. 2. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) is not justified in deleting the above addition holding that the entire sale proceeds has been transferred

ABANI PATTANAYAK,BHUBANESWAR vs. ACIT, INTERNATIONAL TAXATION, BHUBANESWAR

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

ITA 54/CTK/2023[2012-13]Status: HeardITAT Cuttack18 May 2023AY 2012-13
For Appellant: Shri Biswojit Sahoo, CAFor Respondent: Shri Kishore Ch. Mohanty, Sr. DR

Transfer Pricing Act, as part performance as required from the side of the assessee, has fully been complied with being

ASHWIN KUMAR AGARWAL,CUTTACK vs. DCIT ASMNT CIRCLE-2(1)CUTTACK, CUTTACK

In the result, appeal of the assessee is allowed

ITA 507/CTK/2024[2016-17]Status: DisposedITAT Cuttack13 Dec 2024AY 2016-17
Section 10(38)Section 143(3)Section 68

price was paid by cheque and respondent’s bank account has been debited. The shares were also transferred into respondent

LALIT KUMAR JALAN,JALAN PHARMACEUTICALS vs. ITO WARD-1(1), CUTTACK

In the result, appeal of the assessee is allowed with the directions

ITA 335/CTK/2024[2018-19]Status: HeardITAT Cuttack17 Oct 2024AY 2018-19
Section 142(1)Section 50C

price after considering the above negative factors attached to the land. However, the stamp authorities had ignored all these factors and valued the property solely based on the circle rate and no concession was given towards these negative factors. The AO after receiving the objections from the assessee towards the value adopted by stamp duty authorities, in terms

LORAMITRA RATH,KAIRAPARI KOTSAHI, TANGI vs. DCIT (CIRCLE-1(1), CUTTACK

The appeal is allowed

ITA 314/CTK/2023[2015-16]Status: HeardITAT Cuttack05 Sept 2024AY 2015-16

Bench: Before Shri George Mathan, Judicial & Manish Agarwal Manish Agarwalassessment Year : 2015-16 Loramitra Loramitra Rath, Rath, Kairapari Kairapari Vs. Dcit, Circle Dcit, Circle-1(1), Kotsahi, Tangi, Cuttack Kotsahi, Tangi, Cuttack Cuttack Pan/Gir No. No.Aebpr 6065 H (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri Purnendhu Bhusan Mohanty, Ca Purnendhu Bhusan Mohanty, Ca Revenue By : Shri S.C.Mohanty, Sr S.C.Mohanty, Sr Dr

For Appellant: Shri Purnendhu Bhusan Mohanty, CAFor Respondent: Shri S.C.Mohanty, Sr
Section 48

transfer accrued to the assessee, there was diversion of the entire consideration at source before it became income in the hands of the assessee. Further, reliance is placed on the judgements of ACIT Vs Emaar MGF Construction Pvt. Ltd (ITAT Delhi) ITA No. 928/Del/2016 and Shroff Eye Centre vs. ACIT (ITAT Delhi). For the sake of brevity, the relevant portions

DCIT CENTRAL CIRCLE-2, BHUBANESWAR vs. M/S. HOTEL SUKHAMAYA PVT. LTD, BHUBANESWAR

In the result, all the three appeals of the Revenue are dismissed

ITA 205/CTK/2022[2009-10]Status: DisposedITAT Cuttack18 Sept 2024AY 2009-10
Section 132Section 269SSection 271D

price and credited to the said fund were first liable to be used in adjusting the losses of the respondent society in the working year; thereafter in the repayment of initial loan from the Industrial Finance Corporation of India and then for redeeming the Government share and only in the event of any balance being left, it was liable

DCIT CENTRAL CIRCLE-2, BHUBANESWAR vs. M/S. HOTEL SUKHAMAYA PVT. LTD, BHUBANESWAR

In the result, all the three appeals of the Revenue are dismissed

ITA 206/CTK/2022[2012-13]Status: DisposedITAT Cuttack18 Sept 2024AY 2012-13
Section 132Section 269SSection 271D

price and credited to the said fund were first liable to be used in adjusting the losses of the respondent society in the working year; thereafter in the repayment of initial loan from the Industrial Finance Corporation of India and then for redeeming the Government share and only in the event of any balance being left, it was liable

RASHI AGRAWAL,CUTTACKI vs. INCOME TAX OFFICER, CUTTACK

In the result, appeal of the assessee allowed

ITA 56/CTK/2023[2014-15]Status: HeardITAT Cuttack04 May 2023AY 2014-15
For Appellant: Shri Keshav Dubey, CAFor Respondent: Shri S.C.Mohanty, Sr. DR
Section 10(38)

price appearing on the exchange portal and at the point of time of sale of equity shares, companies were not marked as shell companies by SEBI and nor the trading of these scrips were suspended. The assessee also deserves to succeed on the legal ground as no opportunity was awarded to cross examination the third person which were allegedly found

MR. BICHITRANANDA ROUT,SHANKARPUR, CUTTACK vs. INCOME TAX OFFICER, WARD-2(1), CUTTACK

In the result, appeal of the assessee stands dismissed

ITA 60/CTK/2024[2017-18]Status: HeardITAT Cuttack10 Jul 2024AY 2017-18
For Appellant: Shri B.R.PandaFor Respondent: Shri S.C.Mohanty
Section 115BSection 44ASection 69A

transferring or receiving SBNs is only after the ‘appointed day’ which is 31.12.2016. In view of the above, there is no violation by the assessee of any law in accepting SBNs for the purpose of cash sales and considering it to be a due discharge of debt. Furthermore, even the CBDT had issued various Standard Operating Procedures (SOPs) instructing

M/S. SHREE BALAJI ENGICONS PVT. LTD.,BELPAHAR, JHARSUGUDA vs. DCIT, CENTRAL CIRCLE-1(1), SAMBALPUR, SAMBALPUR

In the result, appeals of the assesee in IT(SS)A No

ITA 89/CTK/2023[2017-18]Status: DisposedITAT Cuttack07 Jan 2025AY 2017-18

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

Section 153ASection 194CSection 80Section 801A

transferred to their constituents. Therefore, the joint venture or the consortium was only a paper entity and has not executed in contract itself. They have also not offered any income out of the work 16 IT(SS)A No.77 & ITA Nos.320,296,88, 141,89,142,13/CTK/2023 &CO No.02/CTK/2023 executed by its constituents, nor did they claim any deductions

ACIT, CENTRAL CIRCLE, SAMBALPUR, SAMBALPUR vs. M/S. SHREE BALAJI ENGICONS PVT. LTD., JHARSUGUDA

In the result, appeals of the assesee in IT(SS)A No

ITA 142/CTK/2023[2017-18]Status: DisposedITAT Cuttack07 Jan 2025AY 2017-18

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

Section 153ASection 194CSection 80Section 801A

transferred to their constituents. Therefore, the joint venture or the consortium was only a paper entity and has not executed in contract itself. They have also not offered any income out of the work 16 IT(SS)A No.77 & ITA Nos.320,296,88, 141,89,142,13/CTK/2023 &CO No.02/CTK/2023 executed by its constituents, nor did they claim any deductions

M/S. SHREE BAALAJI ENGICONS LIMITED,JHARSUGUDA vs. DEPUTY COMMISSIONER OF INCOME TAX ( CENTRAL CIRCLE-1(1), SAMBALPUR

In the result, appeals of the assesee in IT(SS)A No

ITA 296/CTK/2023[2013-14]Status: DisposedITAT Cuttack07 Jan 2025AY 2013-14

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

Section 153ASection 194CSection 80Section 801A

transferred to their constituents. Therefore, the joint venture or the consortium was only a paper entity and has not executed in contract itself. They have also not offered any income out of the work 16 IT(SS)A No.77 & ITA Nos.320,296,88, 141,89,142,13/CTK/2023 &CO No.02/CTK/2023 executed by its constituents, nor did they claim any deductions

M/S. SHREE BALAJI ENGICONS PVT. LTD.,BELPAHAR, JHARSUGUDA vs. ACIT, CENTRAL CIRCLE-1(1), SAMBALPUR, SAMBALPUR

In the result, appeals of the assesee in IT(SS)A No

ITA 88/CTK/2023[2016-17]Status: DisposedITAT Cuttack07 Jan 2025AY 2016-17

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

Section 153ASection 194CSection 80Section 801A

transferred to their constituents. Therefore, the joint venture or the consortium was only a paper entity and has not executed in contract itself. They have also not offered any income out of the work 16 IT(SS)A No.77 & ITA Nos.320,296,88, 141,89,142,13/CTK/2023 &CO No.02/CTK/2023 executed by its constituents, nor did they claim any deductions

ACIT, CENTRAL CIRCLE, SAMBALPUR, SAMBALPUR vs. M/S. SHREE BALAJI ENGICONS PVT. LTD., JHARSUGUDA

In the result, appeals of the assesee in IT(SS)A No

ITA 141/CTK/2023[2016-17]Status: DisposedITAT Cuttack07 Jan 2025AY 2016-17

Bench: Shri George Mathan & Shri Manish Agarwalit(Ss)A No.77/Ctk/2023

Section 153ASection 194CSection 80Section 801A

transferred to their constituents. Therefore, the joint venture or the consortium was only a paper entity and has not executed in contract itself. They have also not offered any income out of the work 16 IT(SS)A No.77 & ITA Nos.320,296,88, 141,89,142,13/CTK/2023 &CO No.02/CTK/2023 executed by its constituents, nor did they claim any deductions