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22 results for “transfer pricing”+ Section 142A(6)clear

Sorted by relevance

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Key Topics

Section 153A42Addition to Income17Section 14814Reassessment14Section 143(1)8Section 153C8Section 153D7Section 1537Section 143(3)7

PR. COMMISSIONER OF INCOME TAX -7 vs. SUMITOMO CORPORATION INDIA (P) LTD.

ITA/52/2023HC Delhi02 Sept 2024

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE RAVINDER DUDEJA

Transfer Pricing Officer is received by him.] (6) Nothing contained in sub-sections (1) [, (1-A)] and (2) shall apply to the following classes of assessments, reassessments and recomputation which may, subject to the provisions of [sub-sections (3), (5) and (5-A)], be completed— (i) where the assessment, reassessment or recomputation is made Digitally Signed By:KAMLESH KUMAR Signing

THE PR. COMMISSIONER OF INCOME TAX -6 vs. MICROSOFT INDIA ( R & D) PVT. LTD.

ITA/993/2019HC Delhi02 Mar 2020

Bench: HON'BLE MR. JUSTICE VIPIN SANGHI,HON'BLE MR. JUSTICE SANJEEV NARULA

Transfer Pricing Officer is received by him.] (6) Nothing contained in sub-sections (1) [, (1-A)] and (2) shall apply to the following classes of assessments, reassessments and recomputation which may, subject to the provisions of [sub-sections (3), (5) and (5-A)], be completed— (i) where the assessment, reassessment or recomputation is made Digitally Signed By:KAMLESH KUMAR Signing

Showing 1–20 of 22 · Page 1 of 2

Section 696
Disallowance5
Natural Justice3

THE PR. COMMISSIONER OF INCOME TAX -6 vs. MARUTI SUZUKI INDIA LTD.

ITA/995/2019HC Delhi02 Mar 2020

Bench: HON'BLE MR. JUSTICE VIPIN SANGHI,HON'BLE MR. JUSTICE SANJEEV NARULA

Transfer Pricing Officer is received by him.] (6) Nothing contained in sub-sections (1) [, (1-A)] and (2) shall apply to the following classes of assessments, reassessments and recomputation which may, subject to the provisions of [sub-sections (3), (5) and (5-A)], be completed— (i) where the assessment, reassessment or recomputation is made Digitally Signed By:KAMLESH KUMAR Signing

BIJAY KUMAR SONI,NEW DELHI vs. DCIT, CENTRAL CIRCLE-14, NEW DELHI

The appeal of the Revenue is dismissed as infructuous

ITA 1883/DEL/2023[2017-18]Status: DisposedITAT Delhi06 Sept 2024AY 2017-18

Bench: Dr. B. R. R. Kumarsh. Sudhir Kumarita No. 1883/Del/2023 : Asstt. Year : 2017-18 Bijay Kumar Soni, Vs Dcit, C/O Anil Jain Dd & Co., Central Circle-14, 611, Surya Kiran Building, 19, New Delhi-110055 K. G. Marg, New Delhi-110001 (Appellant) (Respondent) Pan No. Aolps5917H Ita No. 2144/Del/2023 : Asstt. Year : 2017-18 Dcit, Vs Bijay Kumar Soni, Central Circle-14, 61/14, Block No. 61, Ram Jas, New Delhi-110055 Karol Bagh, New Delhi-110005 (Appellant) (Respondent) Pan No. Aolps5917H Assessee By : Sh. Anil Jain, Ca Revenue By : Ms. Monika Dhami, Cit-Dr Date Of Hearing: 01.08.2023 Date Of Pronouncement: 06.09.2023 Order Per Dr. B. R. R. Kumar:

For Appellant: Sh. Anil Jain, CAFor Respondent: Ms. Monika Dhami, CIT-DR
Section 139Section 143Section 143(3)Section 144Section 147Section 148Section 153CSection 254Section 263Section 264

Transfer Pricing Officer is received by him.] (6) Nothing contained in sub-sections (1) 50[, (1A)] and (2) shall apply to the following classes of assessments, reassessments and recomputation which may, subject to the provisions of 51[sub-sections (3), (5) and (5A)], be completed— (i) where the assessment, reassessment or recomputation is made on the assessee or any person

DCIT CENTRAL CIRCLE-14, NEW DELHI vs. SH. VIJAY KUMAR SONI, NEW DELHI

The appeal of the Revenue is dismissed as infructuous

ITA 2144/DEL/2023[2017-18]Status: DisposedITAT Delhi06 Sept 2024AY 2017-18

Bench: Dr. B. R. R. Kumarsh. Sudhir Kumarita No. 1883/Del/2023 : Asstt. Year : 2017-18 Bijay Kumar Soni, Vs Dcit, C/O Anil Jain Dd & Co., Central Circle-14, 611, Surya Kiran Building, 19, New Delhi-110055 K. G. Marg, New Delhi-110001 (Appellant) (Respondent) Pan No. Aolps5917H Ita No. 2144/Del/2023 : Asstt. Year : 2017-18 Dcit, Vs Bijay Kumar Soni, Central Circle-14, 61/14, Block No. 61, Ram Jas, New Delhi-110055 Karol Bagh, New Delhi-110005 (Appellant) (Respondent) Pan No. Aolps5917H Assessee By : Sh. Anil Jain, Ca Revenue By : Ms. Monika Dhami, Cit-Dr Date Of Hearing: 01.08.2023 Date Of Pronouncement: 06.09.2023 Order Per Dr. B. R. R. Kumar:

For Appellant: Sh. Anil Jain, CAFor Respondent: Ms. Monika Dhami, CIT-DR
Section 139Section 143Section 143(3)Section 144Section 147Section 148Section 153CSection 254Section 263Section 264

Transfer Pricing Officer is received by him.] (6) Nothing contained in sub-sections (1) 50[, (1A)] and (2) shall apply to the following classes of assessments, reassessments and recomputation which may, subject to the provisions of 51[sub-sections (3), (5) and (5A)], be completed— (i) where the assessment, reassessment or recomputation is made on the assessee or any person

MAHAVIR TRANSMISSION LTD,NEW DELHI vs. DCIT, CENTRAL CIRCLE-25, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 2632/DEL/2022[2017-18]Status: DisposedITAT Delhi02 Jul 2024AY 2017-18

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Subhra J. Chakraborty, CIT-DR
Section 153Section 153ASection 153D

6) and (7) of section 23A, sub-section (5) of section 24, section 34AA, section 35 and section 37 of the Wealth-tax Act, 1957 (27 of 1957), shall, with necessary modifications, ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. apply in relation to such reference as they apply in relation to a reference made by the Assessing Officer under

MAHAVIR TRANSMISSION LTD,NEW DELHI vs. DCIT, CENTRAL CIRCLE-25, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 2634/DEL/2022[2019-20]Status: DisposedITAT Delhi02 Jul 2024AY 2019-20

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Subhra J. Chakraborty, CIT-DR
Section 153Section 153ASection 153D

6) and (7) of section 23A, sub-section (5) of section 24, section 34AA, section 35 and section 37 of the Wealth-tax Act, 1957 (27 of 1957), shall, with necessary modifications, ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. apply in relation to such reference as they apply in relation to a reference made by the Assessing Officer under

DCIT, CENTRAL CIRCLE-25, NEW DELHI vs. MAHAVEER TRANSMISSION LTD, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 2846/DEL/2022[2019-20]Status: DisposedITAT Delhi02 Jul 2024AY 2019-20

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Subhra J. Chakraborty, CIT-DR
Section 153Section 153ASection 153D

6) and (7) of section 23A, sub-section (5) of section 24, section 34AA, section 35 and section 37 of the Wealth-tax Act, 1957 (27 of 1957), shall, with necessary modifications, ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. apply in relation to such reference as they apply in relation to a reference made by the Assessing Officer under

MAHAVIR TRANSMISSION LTD,NEW DELHI vs. DCIT, CENTRAL CORCLE-25, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 2633/DEL/2022[2018-19]Status: DisposedITAT Delhi02 Jul 2024AY 2018-19

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Subhra J. Chakraborty, CIT-DR
Section 153Section 153ASection 153D

6) and (7) of section 23A, sub-section (5) of section 24, section 34AA, section 35 and section 37 of the Wealth-tax Act, 1957 (27 of 1957), shall, with necessary modifications, ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. apply in relation to such reference as they apply in relation to a reference made by the Assessing Officer under

MAHAVIR TRANSMISSIN LTD ,NEW DELHI vs. DCIT, CENTRAL CIRCLE-25 , NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 2635/DEL/2022[2020-21]Status: DisposedITAT Delhi02 Jul 2024AY 2020-21

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Subhra J. Chakraborty, CIT-DR
Section 153Section 153ASection 153D

6) and (7) of section 23A, sub-section (5) of section 24, section 34AA, section 35 and section 37 of the Wealth-tax Act, 1957 (27 of 1957), shall, with necessary modifications, ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. apply in relation to such reference as they apply in relation to a reference made by the Assessing Officer under

DCIT, CENTRAL CIRCLE-25, NEW DELHI vs. MAHAVEER TRANSMISSION LTD, NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 2844/DEL/2022[2017-18]Status: DisposedITAT Delhi02 Jul 2024AY 2017-18

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Subhra J. Chakraborty, CIT-DR
Section 153Section 153ASection 153D

6) and (7) of section 23A, sub-section (5) of section 24, section 34AA, section 35 and section 37 of the Wealth-tax Act, 1957 (27 of 1957), shall, with necessary modifications, ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. apply in relation to such reference as they apply in relation to a reference made by the Assessing Officer under

DCIT, CENTRAL CIRCLE-25, NEW DELHI vs. MAHAVEER TRANSMISSION LTD., NEW DELHI

In the result, the all appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 2845/DEL/2022[2018-19]Status: DisposedITAT Delhi02 Jul 2024AY 2018-19

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Subhra J. Chakraborty, CIT-DR
Section 153Section 153ASection 153D

6) and (7) of section 23A, sub-section (5) of section 24, section 34AA, section 35 and section 37 of the Wealth-tax Act, 1957 (27 of 1957), shall, with necessary modifications, ITA Nos. 2844 to 2846/Del/2022 Mahavir Transmission Ltd. apply in relation to such reference as they apply in relation to a reference made by the Assessing Officer under

DCIT, NEW DELHI vs. SMT. URVASHI TALLA, NEW DELHI

In the result the Revenue’s appeal is dismissed

ITA 3820/DEL/2014[2009-10]Status: DisposedITAT Delhi24 Feb 2020AY 2009-10

Bench: Shri H.S. Sidhu & Shri Prashant Maharishi

For Appellant: Sh. Nagesh Bahel, AdvocateFor Respondent: Sh. R.K. Gupta, Addl. CIT(DR)
Section 142ASection 48

6. We have heard both the parties and perused the impugned order of the Ld. CIT(A) alongwith the order passed by the ITAT, ‘H’ Bench New Delhi vide its order 30.6.2015 in Revenue’s appeal in ITA No. 5698/Del/2014 i.e. ACIT vs. Smt. Usha Rani Talla and in Assessee’s appeal being ITA No. 5974/Del/2014

DCIT, NEW DELHI vs. SMT. USHA RANI TALLA, NEW DELHI

In the result the Revenue’s appeal is dismissed

ITA 3823/DEL/2014[2005-06]Status: DisposedITAT Delhi24 Feb 2020AY 2005-06

Bench: Shri H.S. Sidhu & Shri Prashant Maharishi

For Appellant: Sh. Nagesh Bahel, AdvocateFor Respondent: Sh. R.K. Gupta, Addl. CIT(DR)
Section 142ASection 48

6. We have heard both the parties and perused the impugned order of the Ld. CIT(A) alongwith the order passed by the ITAT, ‘H’ Bench New Delhi vide its order 30.6.2015 in Revenue’s appeal in ITA No. 5698/Del/2014 i.e. ACIT vs. Smt. Usha Rani Talla and in Assessee’s appeal being ITA No. 5974/Del/2014

SANGITA KSHETRY,NOIDA vs. ACIT,CIRCLE INT.TAX. 2(1)(2), NEW DELHI

In the result, the appeal of the assesses in ITA 1876/Del/2023, ITA

ITA 1876/DEL/2023[2016-17]Status: DisposedITAT Delhi19 May 2025AY 2016-17

Bench: Sh. C.N. Prasad & Sh. Naveen Chandraassessment Year: 2016-17

Section 148

price with Toshiba Corporation was Rs. 248.12 per share. 21. Thus, it is submitted that the substance of transaction is that the Assessee has transferred the shares she held in UEM India Pvt. Ltd. The company UEM India Pvt. Ltd. continued to hold the asset which were in its balance sheet before transfer of the shares and after transfer

HERSH VARDHAN KSHETRY,NOIDA vs. ACIT, CIRCLE INT. TAX. 2(1)(2), NEW DELHI

In the result, the appeal of the assesses in ITA 1876/Del/2023, ITA

ITA 1877/DEL/2023[2016-17]Status: DisposedITAT Delhi19 May 2025AY 2016-17

Bench: Sh. C.N. Prasad & Sh. Naveen Chandraassessment Year: 2016-17

Section 148

price with Toshiba Corporation was Rs. 248.12 per share. 21. Thus, it is submitted that the substance of transaction is that the Assessee has transferred the shares she held in UEM India Pvt. Ltd. The company UEM India Pvt. Ltd. continued to hold the asset which were in its balance sheet before transfer of the shares and after transfer

NINA KSHETRY,NOIDA vs. ACIT, CIRCLE INT.TAX. 2(1)(2), NEW DELHI

In the result, the appeal of the assesses in ITA 1876/Del/2023, ITA

ITA 1878/DEL/2023[2016-17]Status: DisposedITAT Delhi19 May 2025AY 2016-17

Bench: Sh. C.N. Prasad & Sh. Naveen Chandraassessment Year: 2016-17

Section 148

price with Toshiba Corporation was Rs. 248.12 per share. 21. Thus, it is submitted that the substance of transaction is that the Assessee has transferred the shares she held in UEM India Pvt. Ltd. The company UEM India Pvt. Ltd. continued to hold the asset which were in its balance sheet before transfer of the shares and after transfer

BIMLA,DELHI vs. ITO WARD-38(5), NEW DELHI

In the result, the appeal filed by the assessee is partly allowed

ITA 7973/DEL/2019[2014-15]Status: DisposedITAT Delhi26 Nov 2024AY 2014-15

Bench: Shri S.Rifaur Rahman & Shri Sudhir Pareekbimla, Vs. Ito, Ward 38 (5), H.No.143, Village Hamidpur, New Delhi. Delhi – 110 036. (Pan : Bpdpb9344B) (Appellant) (Respondent) Assessee By : Shri Gautam Jain, Advocate Shri Ankit Kumar, Advocate Revenue By : Shri Kanv Bali, Sr. Dr Date Of Hearing : 18.09.2024 Date Of Order : 26.11.2024 Order Per S.Rifaur Rahman,Am: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax Appeals-13, New Delhi (Hereinafter Referred To ‘Ld. Cit (A)’) Dated 23.07.2019 For Assessment Year 2014-15. 2. Brief Facts Of The Case Are, Assessee Filed Return Of Income Declaring Total Income Of Rs.2,23,030/- On 14.08.2014. The Return Of Income Was Processed Under Section 143 (1) Of The Income-Tax Act, 1961 (For Short ‘The Act’). The Case Was Selected For Scrutiny Through Cass & Notices

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Shri Kanv Bali, Sr. DR
Section 131Section 143Section 143(2)Section 69

price. In this regard, he brought to our notice pages 116 to 119 of the paper book. He submitted that section 56(2)(vii)(b)(ii) of the Act was amended to provide sub-clause (ii) of the Finance Act, 2013 w.e.f. 01.04.2014. He brought to 8 our notice the extracts from the Memorandum of Finance Bill reported

YOUNG INDIAN,NEW DELHI vs. ACIT(E), NEW DELHI

ITA 1251/DEL/2019[2011-12]Status: DisposedITAT Delhi31 Mar 2022AY 2011-12

Bench: Shri Anil Chaturvedi & Shri Amit Shukla(Through Video Conference)

For Appellant: Shri Saurabh Soparkar, Sr. AdvocateFor Respondent: Shri G.C. Srivastava, Special Counsel
Section 12ASection 143Section 143(3)Section 147Section 28Section 56(2)Section 56(2)(viia)

142A of the Act for the purported determination of the FMV of the immovable properties owned by AJL. 6 ITA No.1251/Del./2019 2. The Appellant prays that the said reference and consequential determination of the purported FMV be held to be illegal. WITHOUT PREJUDICE TO GROUNDS NO. I TO VII GROUND NO. VIII: COMPUTING THE PURPORTED FMV BEYOND THE VALUE

CHAWLA JEWELLERS,NEW DELHI vs. DCIT CENTRAL CIRCLE 19, NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 576/DEL/2023[2018-19]Status: DisposedITAT Delhi08 Nov 2023AY 2018-19

Bench: Dr. B. R. R. Kumarms. Astha Chandra

For Appellant: Sh. I. P. Bansal, Adv. &For Respondent: Sh. Vivek K. Upadhyay, Sr. DR
Section 133Section 133ASection 142ASection 69

6 Chawla Jewellers 7. After accepting the reconciliation, the AO recorded in the notice dated 01.04.2021 that the assessee has submitted a reconciliation where gold and Polki 22kt, 14kt gold and 18kt gold and diamond and they are required to be clubbed together for the purpose of valuation as they have been considered as similar items. 8. The AO show