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3 results for “transfer pricing”+ Section 80clear

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Key Topics

Section 8013Section 80I7Section 143(3)6Section 2634Deduction3Section 144C2Section 92C2Section 92B2Transfer Pricing2Comparables/TP

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

2

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

M/S. THDC INDIA LIMITED,RISHIKESH vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, DEHRADUN

In the result, appeal of the assessee is allowed

ITA 31/DDN/2022[2017-18]Status: DisposedITAT Dehradun18 Feb 2026AY 2017-18

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2017-18] M/S. Thdc India Ltd. Vs Pcit Ganga Bhawan, Aaykar Bhawan, Pragatipuram, Bye Pass 13 A, Subhash Road, Road, Rishikesh, Uttarakhand Uttarakhand-249201 Pan-Aaact7905Q Appellant Respondent Assessee By Shri Jeetan Nagpal, Ca Shri Sanjay Arora, Ca & Ms. Pallavi, Ca Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 18.02.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 27.03.2022 By Ld. Pr. Commissioner Of Income Tax, Dehradun [“Ld. Pcit”] Passed U/S 263 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 30.12.2019 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2017-18. 2. Brief Facts Of The Case Are That The Assessee Is A Joint Venture Company Of Government Of India & Government Of Uttar Pradesh & Engaged In The Business Of Generation & Supply Of Hydro- Electric As Well As Wind Power & Also Engaged In Construction Of Hydro Power Plants. The Return Of Income Was Filed On 30.10.2017, Declaring Total Income Of Inr 6,84,04,420/- After Claiming Deduction U/S 80-Ia Of The Act Of Inr 948,40,76,282/-. The Book Profits Was Shown At Inr 7,84,96,09,382/- & Mat Of Inr 1,67,52,32,236/- Was Paid. The Case Of The Assessee Was Selected For Scrutiny & After Considering The Submissions Made, Total Income Was Assessed At Inr 4,63,78,80,698/- By Making Disallowance Out Of Deduction Claimed U/S 80-Ia Of The Act To The Extent Of Inr 211,15,54,378/- & Further Making Addition Of Inr 245,79,21,900/- On Account Of Late Payment Surcharge On Outstanding Debtors For The Period Of 10 Months Holding The Same As Taxable On Accrual Basis & No Deduction U/S 80Ia Was Allowed On Such Addition.

Section 143(3)Section 263Section 80Section 80I

transfer price of lignite and sale price of electricity in computing relief under Section 801A/80IB? 2. If the answer to the question No. 1 is in favour of appellant, whether the notional tax reimbursement in the case of Unit VII of Thermal Power Station II whose entire income is deductible u/s 80IA should also be taken into account for computing