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8 results for “transfer pricing”+ Section 65(1)clear

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Key Topics

Section 143(3)9Section 808Section 54B7Section 80I6Transfer Pricing6Comparables/TP6Disallowance4Section 92C3Section 144C(5)3

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

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 5/DDN/2022[2017-2018]Status: DisposedITAT Dehradun31 Mar 2022AY 2017-2018
For Appellant: Shri Ajay Vohra, Sr. Advocate &For Respondent: Shri T.S. Mapwal, Sr. DR
Section 143(3)Section 144C(13)Section 92C

1) of the Act. Ground No. 13: Erroneous levy of interest under section 234B of the Act 13.1 The learned AO erred in law and in facts, in levying consequential interest under section 234B of the Act. Ground No. 14: Violation of principles of natural justice 14.1 The learned AO / DRP erred in law and in facts, in ignoring

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

Deduction3
TP Method3
Section 144C2

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)

1, 2008 till August 31, 2009) was approximately 10,000. Therefore, the total volume of loan issue transactions decreased considerably indicating towards scarcity of funds in the global financial markets. Further, out of the total loan transactions, 6,534 transactions were having fixed interest rate structure i.e. during the post crisis period more than 65% of the total transactions were

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)

1, 2008 till August 31, 2009) was approximately 10,000. Therefore, the total volume of loan issue transactions decreased considerably indicating towards scarcity of funds in the global financial markets. Further, out of the total loan transactions, 6,534 transactions were having fixed interest rate structure i.e. during the post crisis period more than 65% of the total transactions were

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

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

In the result, the appeal of the assessee is partly allowed

ITA 7/DDN/2021[2016-17]Status: DisposedITAT Dehradun14 Dec 2021AY 2016-17

Bench: Shri R.K. Panda & Shri V.P. Raoassessment Years: 2016-17

For Appellant: Sh. Ajay Vohra, Sr. AdvocateFor Respondent: Sh. N.S. Jangpangi, CIT/DR
Section 143(3)Section 144C(13)Section 144C(5)Section 44C

transfer pricing adjustment of interest payment on loan. 8. We have heard ld. Sr. Counsel as well as ld. DR and carefully perused the orders of the authorities below on this issue as well asthe decision of this Tribunal in assessee’s own case for the preceding assessment years. At the outset we note that this Tribunal for the assessment

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

65 of the Bombay Land Revenue Code was obtained for the non-agricultural use of the land? If so, when and by whom (the vendor or the vendee)? Whether such permission was in respect of the whole or a portion of the land? If the permission was in respect of a portion of the land and if it was obtained

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

transferred could not be considered a capital asset under the provision of section 2(14)(iii) of the I.T. Act. From the ratio of these judgments. It is quite clear that mere notification of the area In which the assessee’s land was situated as an industrial zone would not alter the character of the land and render into