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4 results for “transfer pricing”+ Section 100clear

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Key Topics

Section 80I15Section 143(3)8Section 808Section 54B7Section 2634Deduction4Section 144C2Section 92C2Section 92B2Transfer Pricing

M/S. UJVN LIMITED,DEHRADUN vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, DEHRADUN

In the result, the appeal of the Assessee is allowed

ITA 25/DDN/2022[2017-18]Status: DisposedITAT Dehradun15 Sept 2023AY 2017-18

Bench: Sh. C. N. Prasad & Shri M. Balaganesh(Through Video Conferencing) M/S. Ujvn Limited, Vs. The Principal Commissioner C/O. Mn/S. Rra Taxindia, Of Income, D-28, South Extension, Aayakar Bhawan, 13A, Part-I, Subhash Road, Dehradun New Delhi (Appellant) (Respondent) Pan: Aaacu6672R Assessee By : Dr. Rakesh Gupta, Adv Shri Somil Aggarwal, Adv Revenue By: Shri N. S. Jangpangi, Cit Dr Date Of Hearing 24/08/2023 Date Of Pronouncement 15/09/2023

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri N. S. Jangpangi, CIT DR
Section 143(3)Section 263Section 801ASection 80I

section 80IA of the Income Tax Act, 1961. 4. That having regard to facts & circumstances of the case, Ld. PCIT has erred in law and on facts in holding that the appellant has inflated its income eligible for deduction u/s 801A by charging total quantity of energy exported @ 1.029/unit as against the approved rate of Rs. 0.805/unit

2
Comparables/TP2

KARAM SAFETY PRIVATE LIMITED,SITARGANJ vs. THE INCOME TAX OFFICER, WARD-2(3)(5), UDHAM SINGH NAGAR

In the result, both the appeals of the assessee are allowed and that of the Stay Applications are dismissed

ITA 24/DDN/2022[2018-19]Status: DisposedITAT Dehradun23 May 2023AY 2018-19

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

For Appellant: Sh. Nageshwar Rao, AdvFor Respondent: Sh. Pramod Verma, CIT DR
Section 143(3)Section 144CSection 80Section 80ISection 92BSection 92C

transfer pricing adjustment should be given effect by disallowing deduction u/s 80IC/Chapter VI-A of the Act. 4. On the facts and circumstances of the case and in law, the Ld. AO/DRP have failed to appreciate that to invoke the provisions of Section 92BA, existence of any 'arrangement' to ‘more than ordinary profits’ between the Appellant and its Associate Enterprise

KARAM SAFETY PRIVATE LIMITED,UDHAM SINGH NAGAR vs. THE INCOME TAX OFFICER, WARD-2(3)(5), UDHAM SINGH NAGAR

In the result, both the appeals of the assessee are allowed and that of the Stay Applications are dismissed

ITA 3/DDN/2022[2017-18]Status: DisposedITAT Dehradun23 May 2023AY 2017-18

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

For Appellant: Sh. Nageshwar Rao, AdvFor Respondent: Sh. Pramod Verma, CIT DR
Section 143(3)Section 144CSection 80Section 80ISection 92BSection 92C

transfer pricing adjustment should be given effect by disallowing deduction u/s 80IC/Chapter VI-A of the Act. 4. On the facts and circumstances of the case and in law, the Ld. AO/DRP have failed to appreciate that to invoke the provisions of Section 92BA, existence of any 'arrangement' to ‘more than ordinary profits’ between the Appellant and its Associate Enterprise

SH. DEVENDRA DUTT PANT,HARIDWAR vs. DCIT , UTTARKAHAND

Appeal is partly allowed in above terms

ITA 149/DDN/2025[2106-2017]Status: DisposedITAT Dehradun14 Jan 2026AY 2106-2017

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwal

For Appellant: Sh. Salil Aggarwal, Sr. Adv. &For Respondent: Sh. A. S. Rana, Sr. DR
Section 133(6)Section 143(3)Section 54BSection 54E

price at which the land was sold and whether the owner would have ever sold the land valuing it as a property yielding agricultural produce on the basis of its yield? At the risk of repetition, we may mention that not all of these factors would be present or absent in any case and that in each case