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4 results for “reassessment”+ Section 270A(3)(i)clear

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Key Topics

Section 14810Section 56(2)8Section 1474Reassessment4Section 2502Section 270A2Section 271A2Section 50C2Section 143(3)2Penalty

B G EXPLORATION & PRODUCTION INDIA LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME, DDIT/ ADIT (INTERNATIONAL TAXATION), CIRCLE-1, DEHRADUN, DEHRADUN, UTTARAKHAND

In the result, both the appeals of the assessee are allowed

ITA 13/DDN/2022[2015-16]Status: DisposedITAT Dehradun27 Dec 2022AY 2015-16

Bench: Sh. Kul Bharatdr. B. R. R. Kumar

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Sh. Mayak Kumar, JCIT, DR
Section 143(3)Section 144C(5)

reassessment. Ground No. 2: Erroneous disallowance of payment made towards intra-group services by Appellant to its Associated Enterprise (“AE”) 2.1 The learned Transfer Pricing Officer ("TPO") / AO / DRP grossly erred in law and on facts by making an upward transfer pricing adjustment of Rs.219,44,33,564 in total towards international transactions pertaining to payment of management service

B G EXPLORATION & PRODUCTION INDIA LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME, DDIT/ ADIT (INTERNATIONAL TAXATION), CIRCLE-1, DEHRADUN, DEHRADUN

2
Addition to Income2
Transfer Pricing2

In the result, both the appeals of the assessee are allowed

ITA 47/DDN/2022[2018-19]Status: DisposedITAT Dehradun27 Dec 2022AY 2018-19

Bench: Sh. Kul Bharatdr. B. R. R. Kumar

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Sh. Mayak Kumar, JCIT, DR
Section 143(3)Section 144C(5)

reassessment. Ground No. 2: Erroneous disallowance of payment made towards intra-group services by Appellant to its Associated Enterprise (“AE”) 2.1 The learned Transfer Pricing Officer ("TPO") / AO / DRP grossly erred in law and on facts by making an upward transfer pricing adjustment of Rs.219,44,33,564 in total towards international transactions pertaining to payment of management service

BHOPAL SINGH CHAUDHARY,SRINAGAR GARHWAL vs. ITO SRINAGAR, SRINAGAR GARHWAL

ITA 5/DDN/2026[2017-18]Status: HeardITAT Dehradun09 Mar 2026AY 2017-18

Bench: Shri Mahavir Singh & Shri Manish Agarwal

Section 147Section 148Section 250Section 270ASection 271ASection 50CSection 56(2)

270A of the Act respectively. 2. Since both the appeals are related to one assessee and against the additions made in reassessment order and consequent levy of penalty u/s 271A of the Act, therefore, they are taken together and ITA No. 236/DDN/2025 & 05/DDN/2026 decided by a common order. First we take assessee’s appeal in ITA No. 236/DDN/2025. ITA No.236/DDN/2025

BHOPAL SINGH CHAUDHARY,DEHRADUN vs. ITO SRINAGAR, SRINAGAR GARHWAL

ITA 236/DDN/2025[2017-18]Status: HeardITAT Dehradun09 Mar 2026AY 2017-18

Bench: Shri Mahavir Singh & Shri Manish Agarwal

Section 147Section 148Section 250Section 270ASection 271ASection 50CSection 56(2)

270A of the Act respectively. 2. Since both the appeals are related to one assessee and against the additions made in reassessment order and consequent levy of penalty u/s 271A of the Act, therefore, they are taken together and ITA No. 236/DDN/2025 & 05/DDN/2026 decided by a common order. First we take assessee’s appeal in ITA No. 236/DDN/2025. ITA No.236/DDN/2025