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14 results for “transfer pricing”+ Section 36(2)clear

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Key Topics

Section 801A63Addition to Income12Section 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

2) of the Act was issued and served on the assessee which was duly responded. As the case was selected for scrutiny on the TP parameters, the required approval was obtained by the Ld. AO from the Pr. Commissioner of Income Tax for referring the case to the Transfer Pricing Officer(‘TPO’). Thereafter, the case was referred

Penalty4
Transfer Pricing3
Section 143(3)2

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

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

36,841/-) to the appellant. iv.) The appellant did not furnish any evidence on record to the effect that remaining lands (Taila) in question were actually cultivated by her. The Assessing Officer also put blind eyes to such a vital evidence and mechanically allowed the claim of exempt long term capital gains without seeking such vital evidences. The appellant

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

36 24 Vibhuti Glass Works vs. CIT [1989] 177 ITR 439 (SC) 37 13 B STATEMENT OF FACTS For the sake of brevity and convenience of this Hon'ble Court the facts of the present case are summarize as follows: 1. The assessee is an individual and held directorship in various companies. The said companies had availed loan facilities from

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 in respect of work executed by it and incurred various expenses for carrying out the work awarded to the joint venture. Therefore, the resultant profit earned by the appellant from carrying out these projects on behalf of the joint ventures is also eligible for deduction under section 80-IA of the Act. 3.11) The appellant in the above paras

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 in respect of work executed by it and incurred various expenses for carrying out the work awarded to the joint venture. Therefore, the resultant profit earned by the appellant from carrying out these projects on behalf of the joint ventures is also eligible for deduction under section 80-IA of the Act. 3.11) The appellant in the above paras

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 in respect of work executed by it and incurred various expenses for carrying out the work awarded to the joint venture. Therefore, the resultant profit earned by the appellant from carrying out these projects on behalf of the joint ventures is also eligible for deduction under section 80-IA of the Act. 3.11) The appellant in the above paras

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 in respect of work executed by it and incurred various expenses for carrying out the work awarded to the joint venture. Therefore, the resultant profit earned by the appellant from carrying out these projects on behalf of the joint ventures is also eligible for deduction under section 80-IA of the Act. 3.11) The appellant in the above paras

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 in respect of work executed by it and incurred various expenses for carrying out the work awarded to the joint venture. Therefore, the resultant profit earned by the appellant from carrying out these projects on behalf of the joint ventures is also eligible for deduction under section 80-IA of the Act. 3.11) The appellant in the above paras

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 in respect of work executed by it and incurred various expenses for carrying out the work awarded to the joint venture. Therefore, the resultant profit earned by the appellant from carrying out these projects on behalf of the joint ventures is also eligible for deduction under section 80-IA of the Act. 3.11) The appellant in the above paras

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 in respect of work executed by it and incurred various expenses for carrying out the work awarded to the joint venture. Therefore, the resultant profit earned by the appellant from carrying out these projects on behalf of the joint ventures is also eligible for deduction under section 80-IA of the Act. 3.11) The appellant in the above paras

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

2. Whether the Ld. CIT(A) was correct in holding that since no addition of unaccounted income has been made, question of levying penalty for violation of section 269SS and 269T does not arise, when the addition on account of cash loan has been duly made and confirmed in the hands of the sister concern of the assessee. 3. Whether

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

2. Whether the Ld. CIT(A) was correct in holding that since no addition of unaccounted income has been made, question of levying penalty for violation of section 269SS and 269T does not arise, when the addition on account of cash loan has been duly made and confirmed in the hands of the sister concern of the assessee. 3. Whether