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15 results for “transfer pricing”+ Penaltyclear

Sorted by relevance

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Key Topics

Section 801A63Addition to Income14Section 269S8Section 153A7Section 807Section 194C7Deduction7Disallowance7Section 271D6

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

ITA 506/CTK/2024[2021-22]Status: DisposedITAT Cuttack19 Aug 2025AY 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

transfer pricing analysis and, in doing so, has ignored the binding decision of the Hon'ble Supreme Court /rendered in the case of CIT v. Jindal Steel & Power Limited [(2024) 460 ITR 162]. 5. That on the facts and circumstances of the case and in law, the Ld. TPO, as well as the Ld. DRP has failed to appreciate that

Section 69A6
Section 143(3)4
Penalty4

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)

transfer the entire sale proceeds to AE to ensure lowest sale price to MC. The assessee failed to justify the rationality of the approach since, the ultimate sale price to MCL is not linked with the cost of either assessee or AE in the entire scheme of arrangement. Further, the assessee's contention that the income of the assessee

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)

transfer the entire sale proceeds to AE to ensure lowest sale price to MC. The assessee failed to justify the rationality of the approach since, the ultimate sale price to MCL is not linked with the cost of either assessee or AE in the entire scheme of arrangement. Further, the assessee's contention that the income of the assessee

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

penalty was levied for unfair trade practice of reversal trades involved in squaring off transaction. This has no relationship with the transaction of purchases and sales carried out by the assessee in the shares of M/s Appu Marketing Manufacturing Ltd. (now known as Ejecta Marketing Limited). Moreover, nowhere in the assessment order it has been alleged by the AO that

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

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

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

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

price agreed between them and JV’s and in turn JV’s has raised the bills to the principal at the rate awarded in the tender. The principal has made the payment to the JV after making TDS and then payments were released to both the constituents according to their bills. Thereafter the returns of income were filed

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

price agreed between them and JV’s and in turn JV’s has raised the bills to the principal at the rate awarded in the tender. The principal has made the payment to the JV after making TDS and then payments were released to both the constituents according to their bills. Thereafter the returns of income were filed

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

price agreed between them and JV’s and in turn JV’s has raised the bills to the principal at the rate awarded in the tender. The principal has made the payment to the JV after making TDS and then payments were released to both the constituents according to their bills. Thereafter the returns of income were filed

ASST. CIT, CENTRAL CIRCLE, SAMBALPUR, AAYAKAR BHAWAN, SAMBALPUR vs. SHREE BALAJI ENGICON LIMITED, BELPAHAR RS

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

ITA 320/CTK/2023[2011-12]Status: DisposedITAT Cuttack07 Jan 2025AY 2011-12

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

Section 153ASection 194CSection 80Section 801A

price agreed between them and JV’s and in turn JV’s has raised the bills to the principal at the rate awarded in the tender. The principal has made the payment to the JV after making TDS and then payments were released to both the constituents according to their bills. Thereafter the returns of income were filed

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

price agreed between them and JV’s and in turn JV’s has raised the bills to the principal at the rate awarded in the tender. The principal has made the payment to the JV after making TDS and then payments were released to both the constituents according to their bills. Thereafter the returns of income were filed

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

price agreed between them and JV’s and in turn JV’s has raised the bills to the principal at the rate awarded in the tender. The principal has made the payment to the JV after making TDS and then payments were released to both the constituents according to their bills. Thereafter the returns of income were filed

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 13/CTK/2023[2018-19]Status: DisposedITAT Cuttack07 Jan 2025AY 2018-19

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

Section 153ASection 194CSection 80Section 801A

price agreed between them and JV’s and in turn JV’s has raised the bills to the principal at the rate awarded in the tender. The principal has made the payment to the JV after making TDS and then payments were released to both the constituents according to their bills. Thereafter the returns of income were filed

SMT. PURNIMA DAS,BHUBANESWAR vs. PR. CIT-1,, BHUBANESWAR

ITA 95/CTK/2022[2017-18]Status: HeardITAT Cuttack16 Feb 2023AY 2017-18

Bench: S/Shri George Mathan & Arun Khodpiaassessment Year : 2017-18 Smt. Purnima Das, C/O. Vs. Pr. Cit, Bhubaneswar-1. Biswajit Das, At-9, Budha Nagar, Budheswari, Bhubaneswar. Pan/Gir No.Aazpd0112 B (Appellant) .. ( Respondent) Assessee By : Shri P.K.Mishra, Ar Revenue By : Shri M.K.Gautam, Cit Dr Date Of Hearing : 16/02/2023 Date Of Pronouncement : 16/02/2023 O R D E R Per Bench This Is An Appeal Filed By The Assessee Against The Order Of The Ld Pr.Cit Passed U./S.263 Of The Act, Dated 12.3.2022 In Appeal No. Itba/Rev/F/Reev5/2021-22/10540634159(1) For The Assessment Year 2017-18. 2. Shri P.K.Mishra, Ld Ar Appeared For The Assessee Assisted By Ms.Sugyanee Kuanr & Ms. Simran Samal, Intern From Birla School Of Law (Bgu), Bhubaneswar & Shri M.K.Gautam, Ld Cit Dr Appeared For The Revenue Assisted By Shri Dharmashoka Panda, Intern From Birla School Of Law (Bgu), Bhubaneswar. 3. It Was Submitted By Ld Ar That The Assessee Is An Individual, Who Is A Professor Of Mathematics At P.N.College, Khurda. The Assessee Had Filed Her Return Of Income For The Relevant Assessment Year On 5.8.2017

For Appellant: Shri P.K.Mishra, ARFor Respondent: Shri M.K.Gautam, CIT DR
Section 142(1)Section 143(3)Section 271D

penalty proceedings u/s.271D had been dropped by the Pr. CIT after considering the reply of the assessee. In regard to taxability on the sale of agricultural land, it was submitted by ld AR that the assessee had purchased 19.180 acres of agricultural land in Chandrabali, Shyampur, Thana: Gurudijhatia, on 22.7.2010. It was the submission that these lands had been purchased