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98 results for “transfer pricing”+ Section 12Aclear

Sorted by relevance

Delhi98Mumbai67Ahmedabad52Bangalore41Calcutta34Lucknow34Kolkata32Pune29Jaipur21Hyderabad21Visakhapatnam13Chandigarh11Agra7Chennai7Indore7Rajkot7Ranchi6Cuttack6Cochin5Telangana5SC4Varanasi4Allahabad3Nagpur3Raipur2Jodhpur2Punjab & Haryana1

Key Topics

Section 153A89Section 12A52Addition to Income42Section 80I31Section 143(3)26Section 153C21Section 15318Section 1117Section 144C14Exemption

RANBAXY LABORATORIES LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, we direct the AO to reduce the book profit u/s 115JB of the Act by the amount of reversal of the provision of Rs

ITA 196/DEL/2013[2008-09]Status: DisposedITAT Delhi25 Apr 2016AY 2008-09

Bench: Sh. I. C.Sudhir Judicialmember & Sh. Prashant Maharishia.Y.: - 2008-09 Ranbaxy Laboratories Ltd. Vs Acit 12Th Floor, Devika Tower, Range -15 6, Nehru Place New Delhi New Delhi Pan No. Aaacr0127N (Appellant) (Respondent)

For Appellant: 1. Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Amrendra Kumar, CIT, DR
Section 143Section 143(3)Section 92D

Section (2) to Section 14A of the Act and sub Rule (1) to Rule 8D of the Rules. 14. The view and legal ratio expressed above is not being elucidated for the first time. The Delhi High Court in Maxopp Investment Ltd. v. CIT [2012] 347 ITR 272/203 Taxman 364/15 taxmann.com 390 has observed:- 'Scope of sub-sections

Showing 1–20 of 98 · Page 1 of 5

14
Disallowance12
TDS11

MANKIND PHARMA LIMITED,DELHI vs. DCIT, CIRCLE-1(1)(1), MEERUT

In the result, the additional Ground No

ITA 2313/DEL/2022[2018-19]Status: DisposedITAT Delhi01 May 2024AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Pradip Kumar Kedia

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Shri Rajesh Kumar, CIT (DR)
Section 143(3)Section 144BSection 144C(13)Section 153(3)Section 270ASection 35Section 80GSection 80I

transfer pricing provisions in the final assessment order is contrary to the position of law and factual matrix and thus requires to be reversed. 38. In essence, it is the case of assessee that revenue has merely alleged existence of arrangement to invoke rigours of Section 80IA(10) of the Act merely on the ground that the eligible units have

GHAZIABAD DEVELOPMENT AUTHORITY,GHAZIABAD vs. DCIT E (CIRCLE), GHAZIABAD

In the result, the appeal of the assessee in ITA

ITA 305/DEL/2023[2018-19]Status: DisposedITAT Delhi07 Feb 2024AY 2018-19

Bench: SHRI M. BALAGANESH (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Section 10Section 11Section 12ASection 143(2)Section 2(15)Section 234A

prices generating profits. Besides the assessee has substantial income in the nature of rental/lease/ hiring income. It is also understood that the disposal of properties by the assessee authority is by several modes including draw of lots lottery and auction. The very nature of such disposal contemplates sale to the highest bidder presumably generating profits or to unidentified persons

GHAZIABAD DEVELOPMENT AUTHORITY,GHAZIABAD vs. DCIT CIRCLE EXEMPTION, GHAZIABAD

In the result, the appeal of the assessee in ITA

ITA 589/DEL/2023[2016-17]Status: DisposedITAT Delhi07 Feb 2024AY 2016-17
Section 10Section 11Section 12ASection 143(2)Section 2(15)Section 234A

prices generating profits. Besides the assessee has substantial income in the nature of rental/lease/ hiring income. It is also understood that the disposal of properties by the assessee authority is by several modes including draw of lots lottery and auction. The very nature of such disposal contemplates sale to the highest bidder presumably generating profits or to unidentified persons

INCOME TAX OFFICER(E) WARD- 2(4), NEW DELHI, CIVIC CENTRE NEW DELHI vs. PRAKASH SEWA TRUST, PASCHIM VIHAR

In the result, the appeal of the Revenue is dismissed

ITA 4305/DEL/2024[2016-17]Status: DisposedITAT Delhi07 Jan 2026AY 2016-17
Section 11Section 12ASection 143(3)

price permissible under prevailing stamp\nduty law. The AO further observed that the entire sale consideration was given to\nother entity as donation. Accordingly, ld. CIT DR submits that assessee is not carried\nout any charitable activity nor any income was ever derived from such land which\nwas sold during the year and further entire consideration was transferred as donation

BAGHPAT BARAUT KHEKRA VIKAS PRADHIKARAN,MEERUT vs. CIT, MEERUT

In the result, the appeal filed by the assessee is dismissed

ITA 3749/DEL/2011[]Status: DisposedITAT Delhi27 Mar 2019

Bench: Shri H.S. Sidhu & Shri O.P. Kantassessment Year: Nil Baghpat Baraut Khekra Vs. Cit, Meerut Vikas Pradhikaran, Meerut Pan: Aaalb0713B (Appellant) (Respondent) Appellant By Sh. Vinod Goel, Adv. Respondent By Sh. Sanjay Goyal, Cit(Dr)

Section 10Section 12A

12A of the Act, which was allowed vide order dated 30.09.2009. It is at this juncture that the first proviso and second proviso were added by the Finance Act, 2008 w.e.f. 01.04.2009, as mentioned hereinabove. Therefore, after insertion of the said proviso, any institution carrying on of any activity in the nature of trade, commerce or business etc. as mentioned

ADOBE SOFTWARE INDIA PVT. LTD.,NOIDA vs. JCIT, NOIDA

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

ITA 2454/DEL/2013[2006-07]Status: DisposedITAT Delhi20 Jan 2016AY 2006-07

Bench: Smt. Diva Singh, Jm & Sh. N. K. Saini, Am Ita No. 2454/Del/2013 : Asstt. Year : 2006-07 Adobe Software India Pvt. Ltd. Vs Joint Commissioner Of Income (Now Amalgamated With Adobe Tax, Range-1, Systems India Pvt. Ltd.), Plot No. Noida 1-1A, City Centre, Sector-25A, Noida (U.P)-201301 (Appellant) (Respondent) Pan No. Aacca2982J Assessee By : Sh. Deepak Chopra & Rohan Khare, Advs. Revenue By : Sh. Amrendra Kumar, Cit Dr Date Of Hearing : 27.10.2015 Date Of Pronouncement : 20.01.2016 Order Per N. K. Saini, Am:

For Appellant: Sh. Deepak Chopra & Rohan Khare, AdvsFor Respondent: Sh. Amrendra Kumar, CIT DR
Section 143(3)Section 144CSection 153Section 170Section 292B

Transfer Pricing documentation requirements. 11. The learned AO/DRP has erred by rejecting certain comparable companies identified by the assessee using turnover less than Rs. 1 Crore as a comparability criterion. 12a. The learned AO/DRP has erred by rejecting certain comparable companies identified by the assessee for having different accounting year (i.e. companies having accounting year other than March

ANAND KUMAR JAIN,NEW DELHI vs. DCIT, CENTRAL CIRCLE- 25, NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 5948/DEL/2018[2015-16]Status: DisposedITAT Delhi30 Jul 2019AY 2015-16

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumar

Section 127Section 132Section 153ASection 153C

transferred on that day to the [Principal Commissioner or] Commissioner and the [Principal Commissioner or] Commissioner may proceed with such applications under that sub-section from the stage at which they were on that day.] (2) Every order granting or refusing registration under clause (b) of sub-section (1) shall be passed before the expiry of six months from

ANAND JAIN HUF,NEW DELHI vs. DCIT, CENTRAL CIRCLE- 25, NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 5945/DEL/2018[2014-15]Status: DisposedITAT Delhi30 Jul 2019AY 2014-15

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumar

Section 127Section 132Section 153ASection 153C

transferred on that day to the [Principal Commissioner or] Commissioner and the [Principal Commissioner or] Commissioner may proceed with such applications under that sub-section from the stage at which they were on that day.] (2) Every order granting or refusing registration under clause (b) of sub-section (1) shall be passed before the expiry of six months from

SATISH DEV JAIN,DELHI vs. DCIT, CENTRAL CIRCLE-25, NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 5955/DEL/2018[2015-16]Status: DisposedITAT Delhi30 Jul 2019AY 2015-16

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumar

Section 127Section 132Section 153ASection 153C

transferred on that day to the [Principal Commissioner or] Commissioner and the [Principal Commissioner or] Commissioner may proceed with such applications under that sub-section from the stage at which they were on that day.] (2) Every order granting or refusing registration under clause (b) of sub-section (1) shall be passed before the expiry of six months from

ANAND KUMAR JAIN,NEW DELHI vs. DCIT, CENTRAL CIRCLE- 25, NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 5947/DEL/2018[2013-14]Status: DisposedITAT Delhi30 Jul 2019AY 2013-14

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumar

Section 127Section 132Section 153ASection 153C

transferred on that day to the [Principal Commissioner or] Commissioner and the [Principal Commissioner or] Commissioner may proceed with such applications under that sub-section from the stage at which they were on that day.] (2) Every order granting or refusing registration under clause (b) of sub-section (1) shall be passed before the expiry of six months from

ANAND KUMAR JAIN,FARIDABAD vs. DCIT, CENTRAL CIRCLE-25, NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 4723/DEL/2018[2014-15]Status: DisposedITAT Delhi30 Jul 2019AY 2014-15

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumar

Section 127Section 132Section 153ASection 153C

transferred on that day to the [Principal Commissioner or] Commissioner and the [Principal Commissioner or] Commissioner may proceed with such applications under that sub-section from the stage at which they were on that day.] (2) Every order granting or refusing registration under clause (b) of sub-section (1) shall be passed before the expiry of six months from

SAJAN KUMAR JAIN,DELHI vs. DCIT,CENTRAL CIRCLE-25, NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 5949/DEL/2018[2013-14]Status: DisposedITAT Delhi30 Jul 2019AY 2013-14

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumar

Section 127Section 132Section 153ASection 153C

transferred on that day to the [Principal Commissioner or] Commissioner and the [Principal Commissioner or] Commissioner may proceed with such applications under that sub-section from the stage at which they were on that day.] (2) Every order granting or refusing registration under clause (b) of sub-section (1) shall be passed before the expiry of six months from

ANAND JAIN HUF,NEW DELHI vs. DCIT, CENTRAL CIRCLE- 25, NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 5946/DEL/2018[2015-16]Status: DisposedITAT Delhi30 Jul 2019AY 2015-16

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumar

Section 127Section 132Section 153ASection 153C

transferred on that day to the [Principal Commissioner or] Commissioner and the [Principal Commissioner or] Commissioner may proceed with such applications under that sub-section from the stage at which they were on that day.] (2) Every order granting or refusing registration under clause (b) of sub-section (1) shall be passed before the expiry of six months from

URMILA DEVI CHARITABLE TRUST,NEW DELHI vs. CIT(E), LUCKNOW

In the result, the appeal of the assessee is allowed

ITA 4136/DEL/2017[2011-12]Status: DisposedITAT Delhi13 Jun 2019AY 2011-12

Bench: Shri G.D.Agrawal, Before Shri G. D.Agrawal & Before Shri G. Before Shri G. D.Agrawal, D.Agrawal & Ms. Suchitra Kamble Ms. Suchitra Kamblems. Suchitra Kamble Ms. Suchitra Kamble

For Appellant: Shri Kapil Goel, AdvocateFor Respondent: Shri S.S. Rana, CIT-DR
Section 12A

transferred on that day to the [Principal Commissioner or] Commissioner and the [Principal Commissioner or] Commissioner may proceed with such applications under that sub-section from the stage at which they were on that day.] (2) Every order granting or refusing registration under clause (b) of sub-section (1) shall be passed before the expiry of six months from

HEMKUNT FOUNDATIONS,GURUGRAM vs. PRINCIPAL COMMISSIONER OF INCOME TAX, (CENTRAL) -1, DELHI, DELHI

In the result, the appeal filed by assessee is allowed and the Stay

ITA 631/DEL/2024[2021-22]Status: DisposedITAT Delhi20 Jun 2025AY 2021-22

Bench: Shri M. Balaganesh & Shri Vimal Kumarassessment Year: 2021-22 & Stay Application No.329Del/2024 ( In Ita No. 631/Del/2024 ) Assessment Year: 2021-22 Hemkunt Foundations, Vs. Principal Commissioner Plot No.809, Second Floor, Income Tax, Rd 42, Sector 42, Central-1, Gurugram, Haryana New Delhi Pin: 122 002 Pan No. Aaath8443C (Appellant) (Respondent)

For Appellant: S/Shri Salil Kapoor, SumitFor Respondent: Shri Sunil Agarwal, Special Counsel and Shivansh Pandya, Jr. Standing
Section 12ASection 133ASection 143(2)Section 80G

transfer u/s 127. This position has been confirmed by a Constitution Bench of Supreme Court in Kashiram Aggarwala Vs UOI ((1965) 56 ITR 14 (SC). [ Attached @ S. No 3 in Revenue's Judgement PB II] D (iv) It is well-settled that non-mentioning of correct section number, or quoting wrong section number in an Order does not invalidate

ACIT, NEW DELHI vs. M/S. LEGACY FOOD PVT. LTD., NEW DELHI

In the result, both appeals of the Revenue are allowed for statistical purposes

ITA 6197/DEL/2016[2011-12]Status: DisposedITAT Delhi28 Feb 2020AY 2011-12

Bench: Shri Amit Shukla & Shri O.P. Kant

Section 143(3)Section 80Section 801CSection 80I

price as defined in clause (ii) of section 92F. (11) The Central Government may, after making such inquiry as it may think fit, direct, by notification in the Official Gazette, that the exemption conferred by this section shall not apply to any class of industrial undertaking or enterprise with effect from such date as it may specify in the notification

ACIT, NEW DELHI vs. M/S. LEGACY FOOD PVT. LTD., NEW DELHI

In the result, both appeals of the Revenue are allowed for statistical purposes

ITA 6196/DEL/2016[2010-11]Status: DisposedITAT Delhi28 Feb 2020AY 2010-11

Bench: Shri Amit Shukla & Shri O.P. Kant

Section 143(3)Section 80Section 801CSection 80I

price as defined in clause (ii) of section 92F. (11) The Central Government may, after making such inquiry as it may think fit, direct, by notification in the Official Gazette, that the exemption conferred by this section shall not apply to any class of industrial undertaking or enterprise with effect from such date as it may specify in the notification

MICRO FINANCE INDUSTRY NETWORK,GURGAON vs. CIT(E), CHANDIGARH

In the result, the appeals of the assessee are allowed for statistical purpose

ITA 5878/DEL/2025[-]Status: DisposedITAT Delhi11 Mar 2026
Section 12ASection 12A(1)(ac)Section 80G

pricing\nand what factors do they consider in choosing\na credit product. To bridge these knowledge\ngaps and understand customers' thoughts and\nperspectives on these issues, customers who\ncalled on MFIN CGRM were surveyed.\nCentre meeting: There has been increasing\nfeedback about the dilution in the culture of\ncentre meetings. Delinquencies arising from\nthe demonetization phase and now Covid

BSC C&C JOINT VENTURE,NEW DELHI vs. DCIT, CIRCLE-61(1), NEW DELHI

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

ITA 2284/DEL/2022[2018-19]Status: DisposedITAT Delhi06 Feb 2024AY 2018-19

Bench: SHRI G.S. PANNU (Vice President), SHRI ANUBHAV SHARMA (Judicial Member)

For Appellant: Sh. Tarandeep Singh, AdvFor Respondent: Sh. Vivek Kumar Upadhyay, Sr. DR
Section 143(3)Section 234BSection 40Section 801A(4)(i)Section 80I

transfer pricing adjustment on account of interest on advance. The Ld. Assessing Officer, National Faceless Assessment Centre, Delhi proceeded to frame draft order under section 144C of the Act dated 25.09.2021. He computed the total income of the assessee at Rs. 30,92,31,440/- as under:- Total income as per return Rs. (-) 3,56,94,313/- Add: Adjustment