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7 results for “transfer pricing”+ Section 83clear

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Key Topics

Section 80I9Section 16Section 92D6Transfer Pricing6Addition to Income6Comparables/TP6Section 2634Section 143(3)3

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

WEATHERFORD OIL TOOLS M E LTD.,DEHRADUN vs. DCIT, CIRCLE- 2, INTL. TAXATION, DEHRADUN

ITA 7334/DEL/2017[2013-14]Status: DisposedITAT Dehradun28 Apr 2025AY 2013-14

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: Sh. Salil Kapoor, Sh. Anil ChachraFor Respondent: Sh. Mithun Shete, Sr. DR
Section 1Section 92D

transfer pricing regulations. Ground No. 4 That Ld CIT(A) erred in law and on facts by failing to appreciate that the functional profile of the Appellants PE is even below a low risk distributor and that the Appellants PE does not assume title of the goods sold in India and merely provides low end coordination support services

ACIT, CIRCLE- II, INTERNATIONAL TAXATION, DEHRADUN vs. WEATHERFORD OIL TOOLS ME LTD., DEHRADUN

ITA 7477/DEL/2017[2013-14]Status: DisposedITAT Dehradun28 Apr 2025AY 2013-14

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: Sh. Salil Kapoor, Sh. Anil ChachraFor Respondent: Sh. Mithun Shete, Sr. DR
Section 1Section 92D

transfer pricing regulations. Ground No. 4 That Ld CIT(A) erred in law and on facts by failing to appreciate that the functional profile of the Appellants PE is even below a low risk distributor and that the Appellants PE does not assume title of the goods sold in India and merely provides low end coordination support services

WEATHERFORD OIL TOOLS M.E. LTD.,NOIDA vs. DCIT, CIRCLE- 2, INTERNATIONAL TAXATION, DEHRADUN

ITA 7848/DEL/2017[2014-15]Status: DisposedITAT Dehradun28 Apr 2025AY 2014-15

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: Sh. Salil Kapoor, Sh. Anil ChachraFor Respondent: Sh. Mithun Shete, Sr. DR
Section 1Section 92D

transfer pricing regulations. Ground No. 4 That Ld CIT(A) erred in law and on facts by failing to appreciate that the functional profile of the Appellants PE is even below a low risk distributor and that the Appellants PE does not assume title of the goods sold in India and merely provides low end coordination support services

ACIT, CIRCLE- II, INTERNATIONAL TAXATION, DEHRADUN vs. WEATHERFORD OIL TOOLS M.E. LTD., DEHRADUN

ITA 417/DEL/2018[2014-15]Status: DisposedITAT Dehradun28 Apr 2025AY 2014-15

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: Sh. Salil Kapoor, Sh. Anil ChachraFor Respondent: Sh. Mithun Shete, Sr. DR
Section 1Section 92D

transfer pricing regulations. Ground No. 4 That Ld CIT(A) erred in law and on facts by failing to appreciate that the functional profile of the Appellants PE is even below a low risk distributor and that the Appellants PE does not assume title of the goods sold in India and merely provides low end coordination support services

WEATHERFORD OIL TOOLS ME LTD.,DEHRADUN vs. ACIT, CIRCLE- II, INTERNATIONAL TAXATION, DEHRADUN

ITA 5647/DEL/2018[2015-16]Status: DisposedITAT Dehradun28 Apr 2025AY 2015-16

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: Sh. Salil Kapoor, Sh. Anil ChachraFor Respondent: Sh. Mithun Shete, Sr. DR
Section 1Section 92D

transfer pricing regulations. Ground No. 4 That Ld CIT(A) erred in law and on facts by failing to appreciate that the functional profile of the Appellants PE is even below a low risk distributor and that the Appellants PE does not assume title of the goods sold in India and merely provides low end coordination support services

ACIT, CIRCLE- II, INTERNATIONAL TAXATION , DEHRADUN vs. WEATHERFORD OIL TOOLS M.E. LTD., DEHRADUN

ITA 5696/DEL/2018[2015-16]Status: DisposedITAT Dehradun28 Apr 2025AY 2015-16

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: Sh. Salil Kapoor, Sh. Anil ChachraFor Respondent: Sh. Mithun Shete, Sr. DR
Section 1Section 92D

transfer pricing regulations. Ground No. 4 That Ld CIT(A) erred in law and on facts by failing to appreciate that the functional profile of the Appellants PE is even below a low risk distributor and that the Appellants PE does not assume title of the goods sold in India and merely provides low end coordination support services