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3 results for “transfer pricing”+ Section 92A(2)clear

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Mumbai45Delhi21Kolkata11Chennai9Bangalore8Hyderabad7Pune3Cuttack3Cochin2Ahmedabad2Indore1Chandigarh1

Key Topics

Transfer Pricing3Addition to Income3Section 40A(2)(b)2TDS2

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

2), ,Chennai held as under: "20. Now, we move on to consider the issue as to whether the assessee has to be taken as tested party for the purpose of determination of ALP or by applying the least complex theory, the AE outside the Country has to be taken as tested party. The Tribunal while considering the said question proceeded

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

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

2)(b) and the aggregate of such transactions was more than Rs. 20.00 Crore, therefore it is submitted that the JV entered into Specified Domestic Transaction (i.e. SOT) within the meaning of section 92BA. During the assessment proceedings, reference u/s 92CA was made by the ld. AO to the jurisdictional Transfer Pricing Officer (TPO). The Ld. TPO after calling various

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)

2)(b) and the aggregate of such transactions was more than Rs. 20.00 Crore, therefore it is submitted that the JV entered into Specified Domestic Transaction (i.e. SOT) within the meaning of section 92BA. During the assessment proceedings, reference u/s 92CA was made by the ld. AO to the jurisdictional Transfer Pricing Officer (TPO). The Ld. TPO after calling various