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5 results for “transfer pricing”+ Section 148clear

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Key Topics

Section 808Section 143(3)6Section 80I6Transfer Pricing4Comparables/TP4Section 144C2Section 92C2Section 92B2Section 144C(5)2

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)

148 –not pressed 6. Ground No. 2 to 7-Transfer Pricing issue: Intra group services: 7. During year, the intra-group services received by the assessee from the Associated Enterprises amounting to Rs.229,61,81,619/- on account of management charges, information technology charges and general administration charges. 8. The said transaction was benchmarked by the appellant in the transfer

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

Deduction2
Reassessment2
Reopening of Assessment2

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)

148 –not pressed 6. Ground No. 2 to 7-Transfer Pricing issue: Intra group services: 7. During year, the intra-group services received by the assessee from the Associated Enterprises amounting to Rs.229,61,81,619/- on account of management charges, information technology charges and general administration charges. 8. The said transaction was benchmarked by the appellant in the transfer

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 Officer 3(2)(2) (“TPO”) for determination of arm’s length price of the specified domestic transactions (“SDT”) / international transactions undertaken by the Applicant. 9. The TPO vide order dated 30 January 2019 held that the applicant has earned more than ordinary profits from its Section 80-IC business and proposed an adjustment of Rs.5

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 Officer 3(2)(2) (“TPO”) for determination of arm’s length price of the specified domestic transactions (“SDT”) / international transactions undertaken by the Applicant. 9. The TPO vide order dated 30 January 2019 held that the applicant has earned more than ordinary profits from its Section 80-IC business and proposed an adjustment of Rs.5

AKRAM,ROORKEE vs. DCIT, CIRCLE, HARIDWAR

Appeal is partly allowed for statistical purposes in above terms

ITA 6373/DEL/2017[2009-10]Status: DisposedITAT Dehradun07 Jan 2025AY 2009-10

Bench: Sh. Satbeer Singh Godara & Sh. Naveen Chandra

For Appellant: NoneFor Respondent: Sh. Mayank Kumar, Addl. CIT DR
Section 142(1)Section 144Section 148

148 of the Act on 22.03.2016 which is stated to be duly served upon the assessee. Howerver the assessee did not respond to this notice. The AO thereafter issued a notice u/s 142(1), pointing out this fact and asking the assessee to show cause as to why the same should not be assessed as income from business. The assessee