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5 results for “transfer pricing”+ Section 90clear

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Key Topics

Section 246A(1)(b)4Transfer Pricing4Section 92C2Section 143(3)2Section 144C(5)2Reassessment2Reopening of Assessment2Disallowance2Comparables/TP

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)

Transfer Pricing Officer, but it is beyond his authority to question the wisdom of Assessee. It is not the prerogative of revenue to direct Assessee to conduct its business in a particular manner. It is also not proper to ask and Assessee to conduct its business in a manner which is understood by the revenue, despite heavy business risk

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

2
TP Method2

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)

Transfer Pricing Officer, but it is beyond his authority to question the wisdom of Assessee. It is not the prerogative of revenue to direct Assessee to conduct its business in a particular manner. It is also not proper to ask and Assessee to conduct its business in a manner which is understood by the revenue, despite heavy business risk

DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, DEHRADUN vs. BG EXPLORATION, MUMBAI

ITA 107/DDN/2024[2011-12]Status: DisposedITAT Dehradun15 Jan 2026AY 2011-12

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal(Through Video Conferencing)

Section 246A(1)(b)Section 92C

90,50,35,760/- and Rs.9,61,7283,910/-; assessment year-wise, respectively. The Assessing Officer thereafter made section 92CA reference(s) to the Transfer Pricing

DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, DEHRADUN vs. BG EXPLORATION PRODUCDTION INDIA LIMITED, MUMBAI

ITA 105/DDN/2024[2012-13]Status: DisposedITAT Dehradun15 Jan 2026AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal(Through Video Conferencing)

Section 246A(1)(b)Section 92C

90,50,35,760/- and Rs.9,61,7283,910/-; assessment year-wise, respectively. The Assessing Officer thereafter made section 92CA reference(s) to the Transfer Pricing

ACIT, CIRCLE- 2, INTERNATIONAL TAXATION, DEHRADUN vs. SOLAR TURBINES INTERNATIONAL CO., BENGALURU

In the result, the appeal of the Revenue is dismissed

ITA 441/DEL/2018[2013-14]Status: DisposedITAT Dehradun29 Apr 2022AY 2013-14

Bench: Dr. B.R.R. Kumar & Sh. Yogesh Kumar U.S.Assessment Year: 2014-15 Solar Turbines International Vs Dcit, Company (Singapore Branch Of Circle-2, Solar Turbines International International Taxation, Company, Usa), Dehradun. 14 Tractor Road, Singapore, C/O Delloitte Haskins & Sells Llp, Deloitte Centre Anchorage- Ii, Richmond Road, Bangalore. (Appellant) (Respondent) Pan No. Aajcs3585J Assessment Year: 2014-15

For Appellant: NoneFor Respondent: Shri T.S. Mapwal, Sr.DR
Section 2(43)Section 40Section 43BSection 90(2)

90(2) of the Act providing for application of beneficial rate of tax as per DTAA had not been applied and hence constituted mistake apparent on record. e) The learned CIT(A) erred in not upholding justice by adjudicating on merits of the rectification application. 2 Erroneous levy of surcharge and education cess a) The learned C1T(A) erred