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56 results for “transfer pricing”+ Section 143(3)clear

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Key Topics

Section 801A63Section 143(3)41Addition to Income40Section 142(1)22Section 26318Disallowance18Section 10(38)16Deduction16Section 14715Long Term Capital Gains

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

143(2) & 142(1) of the Income Tax Act, 1961 were issued and served upon the appellant. In the course of assessment proceeding a reference was made to the Transfer Pricing Authority under section 92CA of the Income 3

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 56 · Page 1 of 3

15
Capital Gains14
Exemption13
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

143(3) r.w.s. 144C(1) of the Act was passed. Against the draft assessment order, the assessee filed objections before the Dispute Resolution Panel which passed an order u/s 144C(5) of the Act upholding the additions proposed by the Ld. TPO. The directions of the Dispute Resolution Panel in this regard relating to the transfer pricing adjustments as mentioned

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 more than the value determined by the stamp authorities. Since till date no report is submitted nor any time limit is provided in section 50C of the Act, assessee should not be punished for such an inordinate delay of almost 4 years which is solely attributable to the valuation officer and is beyond the control of the assessee

ACIT(CIRCLE-1(1),, SAMBALPUR vs. M/S. TRL KROSAKI REFRACTORIES LIMITED, JHARSUGUDHA

In the result, appeals of the revenue for the assessment years 2010-

ITA 261/CTK/2020[2011-12]Status: DisposedITAT Cuttack23 Aug 2022AY 2011-12

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaita No.260 260/Ctk/2020: Assessment Year Assessment Year :2010-2011

For Appellant: S/Shri Ajit Korde/Bunty SharmaFor Respondent: Shri M.K.Gautam, CIT DR
Section 142(1)Section 143(3)Section 144Section 147Section 92C

Transfer Pricing Officer (TPO) was not to be made in the assessment. Other issues were also raised in the notice u/s.142(1) of the Act. It was the submission that the P a g e 3 | 17 M/s. TRL Krosaki Refractories Ltd., Belpahar, Jharsuguda assessee replied to the notice u/s.142(1) of the Act, however, did not give any reply

ACIT,CIRCLE-1(!), SAMBALPUR vs. M/S. TRL KROSAKI REFRACTORIES LIMITED, JHARSUGUDHA

In the result, appeals of the revenue for the assessment years 2010-

ITA 260/CTK/2020[2010-11]Status: DisposedITAT Cuttack23 Aug 2022AY 2010-11

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaita No.260 260/Ctk/2020: Assessment Year Assessment Year :2010-2011

For Appellant: S/Shri Ajit Korde/Bunty SharmaFor Respondent: Shri M.K.Gautam, CIT DR
Section 142(1)Section 143(3)Section 144Section 147Section 92C

Transfer Pricing Officer (TPO) was not to be made in the assessment. Other issues were also raised in the notice u/s.142(1) of the Act. It was the submission that the P a g e 3 | 17 M/s. TRL Krosaki Refractories Ltd., Belpahar, Jharsuguda assessee replied to the notice u/s.142(1) of the Act, however, did not give any reply

ACIT,CIRCLE-1(1), SAMBALPUR vs. M/S. TRL KROSAKI REFRACTORIES LIMITED, JHARASUGUDHA

In the result, appeals of the revenue for the assessment years 2010-

ITA 262/CTK/2020[2012-13]Status: DisposedITAT Cuttack23 Aug 2022AY 2012-13

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaita No.260 260/Ctk/2020: Assessment Year Assessment Year :2010-2011

For Appellant: S/Shri Ajit Korde/Bunty SharmaFor Respondent: Shri M.K.Gautam, CIT DR
Section 142(1)Section 143(3)Section 144Section 147Section 92C

Transfer Pricing Officer (TPO) was not to be made in the assessment. Other issues were also raised in the notice u/s.142(1) of the Act. It was the submission that the P a g e 3 | 17 M/s. TRL Krosaki Refractories Ltd., Belpahar, Jharsuguda assessee replied to the notice u/s.142(1) of the Act, however, did not give any reply

ACIT,CIRCLE-1(1),, SAMBALPUR vs. M/S. TRL KROSAKI REFRACTORIES LIMITED, JHARSUGUDHA

In the result, appeals of the revenue for the assessment years 2010-

ITA 264/CTK/2020[2014-15]Status: DisposedITAT Cuttack23 Aug 2022AY 2014-15

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaita No.260 260/Ctk/2020: Assessment Year Assessment Year :2010-2011

For Appellant: S/Shri Ajit Korde/Bunty SharmaFor Respondent: Shri M.K.Gautam, CIT DR
Section 142(1)Section 143(3)Section 144Section 147Section 92C

Transfer Pricing Officer (TPO) was not to be made in the assessment. Other issues were also raised in the notice u/s.142(1) of the Act. It was the submission that the P a g e 3 | 17 M/s. TRL Krosaki Refractories Ltd., Belpahar, Jharsuguda assessee replied to the notice u/s.142(1) of the Act, however, did not give any reply

ACIT,CIRCLE-1(1), SAMBALPUR, SAMBALPUR vs. M/S. TRL KROSAKI REFRACTORIES LIMITED, JHARSUGUDHA

In the result, appeals of the revenue for the assessment years 2010-

ITA 263/CTK/2020[2013-14]Status: DisposedITAT Cuttack23 Aug 2022AY 2013-14

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaita No.260 260/Ctk/2020: Assessment Year Assessment Year :2010-2011

For Appellant: S/Shri Ajit Korde/Bunty SharmaFor Respondent: Shri M.K.Gautam, CIT DR
Section 142(1)Section 143(3)Section 144Section 147Section 92C

Transfer Pricing Officer (TPO) was not to be made in the assessment. Other issues were also raised in the notice u/s.142(1) of the Act. It was the submission that the P a g e 3 | 17 M/s. TRL Krosaki Refractories Ltd., Belpahar, Jharsuguda assessee replied to the notice u/s.142(1) of the Act, however, did not give any reply

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

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

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

DCIT, CIRCLE-1(1), BHUBANESWAR, BHUBANESWAR vs. M/S. PARADEEP PHOSPHATES LIMITED, BHUBANESWAR

In the result, appeal filed by the revenue is dismissed and that of

ITA 289/CTK/2014[2010-11]Status: DisposedITAT Cuttack04 Aug 2017AY 2010-11

Bench: S/Shri N.S Saini & Pavan Kumar Gadaleassessment Year : 2010-2011

For Appellant: Shri B.K.MohapatraFor Respondent: Shri Kunal Singh, CIT DR
Section 195Section 195(1)Section 195(2)Section 197Section 263Section 40Section 92

Transfer Pricing (TP) assessment for the AY 2010-11 has been completed on 30.01.2014 with "NIL Adjustment" after going through in detail, the transactions of imports from various parties being associated enterprises within the meaning of Section 92 (C) of the Income Tax Act, 1961. Copy of the aforesaid Order is enclosed and marked as Annexure-1 for your kind

MAHANADI COALFIELDS LTD.,SAMBALPUR vs. DCIT, CIRCLE-2(1), SAMBALPUR

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

ITA 174/CTK/2018[2015-16]Status: DisposedITAT Cuttack05 Jun 2020AY 2015-16

Bench: Shri C.M. Garg, Jm & Shri L.P. Sahu, Am आयकर अपीऱ सं./Ita No.174/Ctk/2018 (नििाारण वषा / Assessment Year : 2015 - 2016) Mahanadi Coalfields Ltd., Vs. Dcit, Circle-2(1), Sambalpur Jagriti Vihar, Burla, Sambalpur स्थायी ऱेखा सं./Pan No. : Aabcm 5188 P (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. यनधागररती की ओर से /Assessee By : Shri S.S.Podar, Ca राजस्व की ओर से /Revenue By : Shri S.M.Keshkamat, Citdr सुनवाई की तारीख / Date Of Hearing : 15/01/2020 घोषणा की तारीख/Date Of Pronouncement : 05/06/2020 आदेश / O R D E R Per L.P.Sahu, Am :

For Appellant: Shri S.S.Podar, CAFor Respondent: Shri S.M.Keshkamat, CITDR
Section 143(3)Section 14ASection 32Section 35ESection 37Section 37(1)

143(3) of the 1. T. Act, 1961 was completed vide order dated 31.12.2017 in which the Ld. AO assessed the total income at Rs. 789323.30 Lacs by making substantial additions/disallowances and raising a further tax demand of Rs. 196731.20 Lakhs including interest of Rs. 30349.26 Lakhs u/s, 234B. Subsequently, vide order u/s.154/143(3) dated 31.01.2018 the assessed income

ITO, BHADRAK WARD, BHADRAK vs. DEEPANSU MOHAPATRA, BHADRAK

In the result, Appeals of the revenue in in ITANos

ITA 42/CTK/2020[2014-15]Status: DisposedITAT Cuttack21 Dec 2021AY 2014-15

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am

For Appellant: Shri S.C Mohanty, Sr. DR
Section 10(38)

143(3) and an Assessment order was passed - In meantime, Supreme Court in a case of another employee of same bank passed a dictum that he was entitled to exemption under section 10(10C) on amount received under early retirement scheme - On basis of same, Assessee filed an application before Commissioner seeking to claim exemption under section 10(10C) - Commissioner

ITO, BHADRAK WARD, BHADRAK vs. HIMANSU MOHAPATRA, BHADRAK

In the result, Appeals of the revenue in in ITANos

ITA 44/CTK/2020[2014-15]Status: DisposedITAT Cuttack21 Dec 2021AY 2014-15

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am

For Appellant: Shri S.C Mohanty, Sr. DR
Section 10(38)

143(3) and an Assessment order was passed - In meantime, Supreme Court in a case of another employee of same bank passed a dictum that he was entitled to exemption under section 10(10C) on amount received under early retirement scheme - On basis of same, Assessee filed an application before Commissioner seeking to claim exemption under section 10(10C) - Commissioner

ITO, BHADRAK WARD, BHADRAK vs. DEEPANSU MOHAPATRA, BHADRAK

In the result, Appeals of the revenue in in ITANos

ITA 43/CTK/2020[2015-16]Status: DisposedITAT Cuttack21 Dec 2021AY 2015-16

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am

For Appellant: Shri S.C Mohanty, Sr. DR
Section 10(38)

143(3) and an Assessment order was passed - In meantime, Supreme Court in a case of another employee of same bank passed a dictum that he was entitled to exemption under section 10(10C) on amount received under early retirement scheme - On basis of same, Assessee filed an application before Commissioner seeking to claim exemption under section 10(10C) - Commissioner

ITO, BHADRAK WARD, BHADRAK vs. HIMANSU MOHAPATRA, BHADRAK

In the result, Appeals of the revenue in in ITANos

ITA 45/CTK/2020[2015-16]Status: DisposedITAT Cuttack21 Dec 2021AY 2015-16

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am

For Appellant: Shri S.C Mohanty, Sr. DR
Section 10(38)

143(3) and an Assessment order was passed - In meantime, Supreme Court in a case of another employee of same bank passed a dictum that he was entitled to exemption under section 10(10C) on amount received under early retirement scheme - On basis of same, Assessee filed an application before Commissioner seeking to claim exemption under section 10(10C) - Commissioner

ITO, BHADRAK WARD, BHADRAK vs. SITANSU SEKHAR MOHAPATRA, BHADRAK

In the result, Appeals of the revenue in in ITANos

ITA 38/CTK/2020[2014-15]Status: DisposedITAT Cuttack21 Dec 2021AY 2014-15

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am

For Appellant: Shri S.C Mohanty, Sr. DR
Section 10(38)

143(3) and an Assessment order was passed - In meantime, Supreme Court in a case of another employee of same bank passed a dictum that he was entitled to exemption under section 10(10C) on amount received under early retirement scheme - On basis of same, Assessee filed an application before Commissioner seeking to claim exemption under section 10(10C) - Commissioner

ITO, BHADRAK WARD, BHADRAK vs. ANUPAMA MOHAPATRA, BHADRAK

In the result, Appeals of the revenue in in ITANos

ITA 40/CTK/2020[2014-15]Status: DisposedITAT Cuttack21 Dec 2021AY 2014-15

Bench: Shri C.M. Garg, Jm & Shri Manish Borad, Am

For Appellant: Shri S.C Mohanty, Sr. DR
Section 10(38)

143(3) and an Assessment order was passed - In meantime, Supreme Court in a case of another employee of same bank passed a dictum that he was entitled to exemption under section 10(10C) on amount received under early retirement scheme - On basis of same, Assessee filed an application before Commissioner seeking to claim exemption under section 10(10C) - Commissioner