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12 results for “transfer pricing”+ Section 144B(1)(xvi)clear

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Delhi12Jaipur10Chandigarh7Mumbai7Hyderabad2Nagpur1Bangalore1Lucknow1Ahmedabad1

Key Topics

Section 143(3)33Section 144C(13)9Addition to Income9Section 80I8Section 92C8Section 2638Deduction8Transfer Pricing7Section 144C(5)6

EBRO INDIA PVT.LTD. ,DELHI vs. ACIT CIRCLE-7(1), DELHI

In the result, the ground no 4 raised by the assessee is allowed

ITA 1291/DEL/2022[2018-19]Status: HeardITAT Delhi09 Sept 2024AY 2018-19

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Accountant Member)

For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Shri Rajesh Kumar, CIT DR
Section 143(3)Section 144BSection 144CSection 68

xvi) of sub Section (1) of Section 144B; b) addition under section 68 of the Act has been made without even giving an opportunity by issuing a show cause notice and ; (c) no personal hearing was granted despite petitioner requesting for the same. The Hon’ble High Court quashed the said assessment order passed in violation of section 144B

Section 144B6
Section 144C6
Limitation/Time-bar5

MICROSOFT CORPORATION (INDIA) PRIVATE LIMITED,NEW DELHI vs. DCIT, CIRCLE-16(1), NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 1863/DEL/2022[2018-19]Status: DisposedITAT Delhi28 Feb 2024AY 2018-19

Bench: Shri M. Balaganesh & Shri Yogesh Kumar Usmicrosoft Corporation (India) Vs. Dcit, Pvt. Ltd, Circle-16(1), 807, New Delhi House, New Delhi Barakhamba Road, New Delhi (Appellant) (Respondent) Pan: Aaacm5586C Assessee By : Shri Nageswar Rao & Parth, Adv Revenue By: Shri Rajesh Kumar, Cit(Dr) Date Of Hearing 22/02/2024 Date Of Pronouncement 28/02/2024

For Appellant: Shri Nageswar Rao & Parth, AdvFor Respondent: Shri Rajesh Kumar, CIT(DR)
Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 153Section 153BSection 92C

144b. 6[(1) notwithstanding anything to the contrary contained in any other provision of this act, the assessment, reassessment or recomputation under sub- section (3) of section 143 or under section 144 or under section 147, as the case may be, with respect to the cases referred to in sub-section (2), shall be made in a faceless manner

DCM SHRIIRAM LIMITED,NEW DELHI vs. NEAC, NEW DELHI

ITA 704/DEL/2021[2016-17]Status: DisposedITAT Delhi30 Jun 2025AY 2016-17
Section 115JSection 143(3)Section 250Section 80GSection 80ISection 92C

1) of Order 41 of the Code of Civil Procedure, \"That the\nappellate court has power to allow additional evidence not only if it\nrequires such evidence \"to enable it to pronounce judgment\" but also for\n\"any other substantial cause.\" There may be cases where even though the\ncourt finds that it is able to pronounce judgment

DCM SHRIRAM LIMITED,DELHI vs. ASSESSMENT UNIT, DELHI

ITA 4328/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Jun 2025AY 2020-21
Section 115JSection 143(3)Section 250Section 80GSection 80ISection 92C

1) of Order 41 of the Code of Civil Procedure, \"That the\nappellate court has power to allow additional evidence not only if it\nrequires such evidence \"to enable it to pronounce judgment\" but also for\n\"any other substantial cause.\" There may be cases where even though the\ncourt finds that it is able to pronounce judgment

DCM SHRIRAM LTD,NEW DELHI vs. ACIT, CIRCLE-7(1), NEW DELHI

ITA 2587/DEL/2022[2018-19]Status: DisposedITAT Delhi30 Jun 2025AY 2018-19
Section 115JSection 143(3)Section 250Section 80GSection 80ISection 92C

1) of Order 41 of the Code of Civil Procedure, \"That the\nappellate court has power to allow additional evidence not only if it\nrequires such evidence \"to enable it to pronounce judgment\" but also for\n\"any other substantial cause.\" There may be cases where even though the\ncourt finds that it is able to pronounce judgment

DCIT, NEW DELHI vs. DCM SHRIRAM LTD, NEW DELHI

ITA 927/DEL/2022[2015-16]Status: DisposedITAT Delhi30 Jun 2025AY 2015-16
Section 115JSection 143(3)Section 250Section 80GSection 80ISection 92C

1) of Order 41 of the Code of Civil Procedure, \"That the\nappellate court has power to allow additional evidence not only if it\nrequires such evidence \"to enable it to pronounce judgment\" but also for\n\"any other substantial cause.\" There may be cases where even though the\ncourt finds that it is able to pronounce judgment

SRF LIMITED ,DELHI vs. ACIT, CIRCLE-10(1), DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 1449/DEL/2022[2018-19]Status: DisposedITAT Delhi12 Dec 2025AY 2018-19
For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 80Section 92C

prices at which power was purchased from respective State Electricity Board. 64. In a case where the assessee operates a Wind Power Mill (WPP) unit at Tamil Nadu to generate electricity primarily for consumption by its manufacturing units. During the year, the assessee had transferred the WPP units at effective rate of Rs. 6.35 p.u, based on fact that Tamil

SRF LIMITED,DELHI vs. ASSISTANT / DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 10(1), NEW DELHI, DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 5618/DEL/2024[2021-22]Status: DisposedITAT Delhi12 Dec 2025AY 2021-22
For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 80Section 92C

prices at which power was purchased from respective State Electricity Board. 64. In a case where the assessee operates a Wind Power Mill (WPP) unit at Tamil Nadu to generate electricity primarily for consumption by its manufacturing units. During the year, the assessee had transferred the WPP units at effective rate of Rs. 6.35 p.u, based on fact that Tamil

SRF LIMITED,NEW DELHI vs. ACIT, CIRCLE-10(1), DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 1448/DEL/2022[2017-18]Status: DisposedITAT Delhi12 Dec 2025AY 2017-18
For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 80Section 92C

prices at which power was purchased from respective State Electricity Board. 64. In a case where the assessee operates a Wind Power Mill (WPP) unit at Tamil Nadu to generate electricity primarily for consumption by its manufacturing units. During the year, the assessee had transferred the WPP units at effective rate of Rs. 6.35 p.u, based on fact that Tamil

JONES LANG LASALLE PROPERTY CONSULTANTS (INDIA) PRIVATE LIMITED,DELHI, INDIA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 13(1), DELHI, INDIA

In the result, the appeal of the assessee is allowed and the Stay

ITA 3964/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Jun 2025AY 2020-21

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2020-21 & Stay Application No.61/Del/2025 ( In Ita No. 3964/Del/2024 ) Assessment Year: 2020-21

For Appellant: S/Shri Nageshwar Rao and ParthFor Respondent: ShriDharam Veer Singh, CIT (DR)
Section 142(1)Section 143(2)Section 143(3)Section 144BSection 144CSection 144C(12)Section 144C(13)Section 144C(5)Section 41Section 92

144B of the Act is time barred having been passed beyond the time limit prescribed under section 144C(13) for completion of assessment. 4. In the alternative to ground no. 3, directions issued by Ld. DRP under section 144C(5) have been issued beyond time limit prescribed under section 144C(12). 5. Without prejudice to the above, assessment proceedings which

VENETIAN LDF PROJECTS LLP,GURGAON vs. ACIT CIRCLE-4(1), GURGAON

In the result, grounds raised by the assessee are dismissed

ITA 3533/DEL/2019[2014-15]Status: DisposedITAT Delhi01 May 2025AY 2014-15

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 143(1)Section 143(3)Section 263Section 40A(2)

section 263 of the Act. 45 173 In fact, it is pertinent to note that section 263 nowhere refers to an assessment order passed by the NaFAC under section 144B of the Faceless Assessment Scheme to be subjected to revisionary jurisdiction. It only confers revisionary jurisdiction to revise any order passed by the ‘Assessing Officer’ or the ‘Transfer Pricing Officer

AMAZON SMART COMMERCE SOLUTIONS PRIVATE LIMITED,DELHI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, DELHI-1, DELHI

In the result, grounds raised by the assessee are dismissed

ITA 3533/DEL/2025[2021-22]Status: DisposedITAT Delhi18 Mar 2026AY 2021-22
Section 143(1)Section 143(3)Section 263Section 40A(2)

section 263 of the Act is without jurisdiction and bad in law, since the pre-requisite twin conditions for invoking jurisdiction under the said section have not been fulfilled qua the order of the AO.\nRe (f): Assessment completed by NaFAC cannot be subjected to revisionary proceedings\n166 It is of utmost important to note that in the present case