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15 results for “transfer pricing”+ Section 46clear

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Key Topics

Section 801A63Section 26312Section 26012Addition to Income11Deduction10Section 119Section 269S8Section 153A7Section 807

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

46,025/- was utilised for pert infrastructure activities. Here, your kind attention is invited to the definition of infrastructure facility as stated in section 801A of the Act which reads as follows Explanation For the purposes of this clause, "infrastructure facility" means (a) a road including toll road, a bridge or a mil system: (b) a highway project including housing

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

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

Section 194C7
Disallowance7
Charitable Trust3
ITA 209/CTK/2024[2004-05]Status: DisposedITAT Cuttack25 Sept 2024AY 2004-05
Section 11Section 11(1)(a)Section 12ASection 260Section 263

46,025/- was utilised for pert infrastructure activities. Here, your kind attention is invited to the definition of infrastructure facility as stated in section 801A of the Act which reads as follows Explanation For the purposes of this clause, "infrastructure facility" means (a) a road including toll road, a bridge or a mil system: (b) a highway project including housing

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

46,025/- was utilised for pert infrastructure activities. Here, your kind attention is invited to the definition of infrastructure facility as stated in section 801A of the Act which reads as follows Explanation For the purposes of this clause, "infrastructure facility" means (a) a road including toll road, a bridge or a mil system: (b) a highway project including housing

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

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

46 IT'R 144 (SC). In the decision of CIT vs. Sitaldar Tirathdas 41 ITR 367, Hon'ble Supreme Court has ruled that what is to be subject for taxation is only real income over which the assessee possesses a right and not any other thing. In Somaiya Organo Chemicals Ltd vs CIT 216 ITR 291, the issue considered

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 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

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

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

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

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

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

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