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31 results for “transfer pricing”+ Section 245D(4)clear

Sorted by relevance

Hyderabad43Delhi31Mumbai27Chennai20Chandigarh10Pune10Indore8Agra5Kolkata2Lucknow1Jaipur1Bangalore1SC1

Key Topics

Section 14342Section 153A33Addition to Income29Section 153C20Search & Seizure15Section 13914Section 143(3)9Section 1427Section 686

FISERV INDIA PVT. LTD.,NEW DELHI vs. ACIT, CIRCLE-9(1), NEW DELHI

The appeal is dismissed

ITA 6583/DEL/2019[2013-14]Status: DisposedITAT Delhi03 Jul 2020AY 2013-14

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishifiserv India Private Limited, Vs. Acit, Regus Elegance, Level-2, Jasola Circle-9(1), District Centre, Old Mathura New Delhi Road, Delhi Pan: Aaccr0787L (Appellant) (Respondent)

For Appellant: Shri Sachit Jolly, AdvFor Respondent: Ms. Ashima Neb, Sr. DR
Section 115JSection 143Section 154Section 234B

4) of section 245D, section 250, section 254, section 260, section 262, section 263 or section 264, the amount of tax payable under this Act is reduced or increased, as the case may be, the amount of tax credit allowed under this section shall also be increased or reduced accordingly.] 77[(7) In case of conversion of a private company

Showing 1–20 of 31 · Page 1 of 2

Section 10A6
Bogus Purchases5
Deduction4

DCIT CIRCLE-I(LTU), NEW DELHI vs. DALMIA BHARAT SUGAR AND INDUSTRIES LTD.,, NEW DELHI

Accordingly we dispose of the matters for AY 2007-08 to 2011-12 for the same reasons as under :- i. Thus, For AY 2007-08, Ground no 1 & 2 of the appeal of the ld AO are dismissed

ITA 5405/DEL/2019[2010-11]Status: DisposedITAT Delhi13 Sept 2021AY 2010-11

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Ms. Nidhi Srivatava, CIT DR
Section 153CSection 245

section 153C as it stood in 2014 provides as under :- Assessment of income of any other person.2 153C.3[(1)] Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized

DCIT CIRCLE-I(LTU), NEW DELHI vs. DALMIA BHARAT SUGAR AND INDUSTRIES LTD.,, NEW DELHI

Accordingly we dispose of the matters for AY 2007-08 to 2011-12 for the same reasons as under :- i. Thus, For AY 2007-08, Ground no 1 & 2 of the appeal of the ld AO are dismissed

ITA 5406/DEL/2019[2011-12]Status: DisposedITAT Delhi13 Sept 2021AY 2011-12

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Ms. Nidhi Srivatava, CIT DR
Section 153CSection 245

section 153C as it stood in 2014 provides as under :- Assessment of income of any other person.2 153C.3[(1)] Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized

DCIT CIRCLE-1 LTU, NEW DELHI vs. DALMIA BHARAT SUGAR & INDUSTRIES LTD, NEW DELHI

Accordingly we dispose of the matters for AY 2007-08 to 2011-12 for the same reasons as under :- i. Thus, For AY 2007-08, Ground no 1 & 2 of the appeal of the ld AO are dismissed

ITA 5402/DEL/2019[2007-08]Status: DisposedITAT Delhi13 Sept 2021AY 2007-08

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Ms. Nidhi Srivatava, CIT DR
Section 153CSection 245

section 153C as it stood in 2014 provides as under :- Assessment of income of any other person.2 153C.3[(1)] Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized

DCIT CIRCLE-I(LTU), NEW DELHI vs. DALMIA BHARAT SUGAR AND INDUSTRIES LTD.,, NEW DELHI

Accordingly we dispose of the matters for AY 2007-08 to 2011-12 for the same reasons as under :- i. Thus, For AY 2007-08, Ground no 1 & 2 of the appeal of the ld AO are dismissed

ITA 5401/DEL/2019[2006-07]Status: DisposedITAT Delhi13 Sept 2021AY 2006-07

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Ms. Nidhi Srivatava, CIT DR
Section 153CSection 245

section 153C as it stood in 2014 provides as under :- Assessment of income of any other person.2 153C.3[(1)] Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized

DCIT CIRCLE-I(LTU), NEW DELHI vs. DALMIA BHARAT SUGAR AND INDUSTRIES LTD.,, NEW DELHI

Accordingly we dispose of the matters for AY 2007-08 to 2011-12 for the same reasons as under :- i. Thus, For AY 2007-08, Ground no 1 & 2 of the appeal of the ld AO are dismissed

ITA 5404/DEL/2019[2009-10]Status: DisposedITAT Delhi13 Sept 2021AY 2009-10

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Ms. Nidhi Srivatava, CIT DR
Section 153CSection 245

section 153C as it stood in 2014 provides as under :- Assessment of income of any other person.2 153C.3[(1)] Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized

DCIT CIRCLE-I(LTU), NEW DELHI vs. DALMIA BHARAT SUGAR AND INDUSTRIES LTD.,, NEW DELHI

Accordingly we dispose of the matters for AY 2007-08 to 2011-12 for the same reasons as under :- i. Thus, For AY 2007-08, Ground no 1 & 2 of the appeal of the ld AO are dismissed

ITA 5403/DEL/2019[2008-09]Status: DisposedITAT Delhi13 Sept 2021AY 2008-09

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Ms. Nidhi Srivatava, CIT DR
Section 153CSection 245

section 153C as it stood in 2014 provides as under :- Assessment of income of any other person.2 153C.3[(1)] Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized

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

4) Notwithstanding anything contained in 46[sub-sections (1), (1A), (2), (3) and (3A)], where a reference under sub-section (1) of section 92CA is made during the course of the proceeding for the assessment or reassessment, the period available for completion of assessment or reassessment, as the case may be, under the said 46[sub-sections

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

4) Notwithstanding anything contained in 46[sub-sections (1), (1A), (2), (3) and (3A)], where a reference under sub-section (1) of section 92CA is made during the course of the proceeding for the assessment or reassessment, the period available for completion of assessment or reassessment, as the case may be, under the said 46[sub-sections

THE BANK OF TOKYO MISTUBISHI UFJ LTD.,,NEW DELHI vs. DCIT (INTERNATIONAL TAXATION), NEW DELHI

In the result, appeal of the assessee is partly allowed

ITA 4548/DEL/2016[2008-09]Status: DisposedITAT Delhi27 Feb 2018AY 2008-09

Bench: Shri N.K. Saini & Before Mr. Bhavnesh Saini

For Appellant: Sh. P.J. Pardiwala, Sr. AdvFor Respondent: Sh. G.K. Dhall, CIT DR (Intl
Section 139(1)Section 234DSection 44C

transfer pricing adjustment with respect to ECB syndication fee in the return of income. Therefore, the assessee has already offered to tax an amount of Rs 16,73,70,200 (Rs.14,58,92,297 + Rs 2,14,77,903) as fee received by the Indian PE of the assessee from its HO/other overseas branches for the services performed in relation

M/S VARDAAN FASHION,NEW DELHI vs. JCIT, NEW DELHI

In the result ground No. 3 of the appeal of the assessee is dismissed

ITA 1143/DEL/2013[2007-08]Status: DisposedITAT Delhi08 Jul 2016AY 2007-08

Bench: I.C.Sudhir & Shri Prashant Maharishivardan Fashions, Jcit, E-1/7, 2Nd Floor, East Patel Range-33, Vs. Nagar, New Delhi New Delhi Pan:Aacfv0423H (Appellant) (Respondent) Acit, Vardan Fashions, Circle-33(1) E-1/7, 2Nd Floor, East Patel Vs. New Delhi Nagar, New Delhi Pan:Aacfv0423H (Appellant) (Respondent)

For Appellant: Sh. Ajay Wadhwa, AdvFor Respondent: Sh. Vijay Verma, CIT DR
Section 142Section 40

245D(4) dated 29.07.2013 for AY 2009- 10 to 2011 -12 in case of assessee as well as one Shri Inderpal Singh Wadhawan. He relied heavily on the order wherein the assessee has himself offered 1% of total purchases in statement of facts as additional income that was enhanced by Income Tax Settlement Commission. He referred to para

ACIT, NEW DELHI vs. M/S VARDAN FASHION, NEW DELHI

In the result ground No. 3 of the appeal of the assessee is dismissed

ITA 950/DEL/2013[2007-08]Status: DisposedITAT Delhi08 Jul 2016AY 2007-08

Bench: I.C.Sudhir & Shri Prashant Maharishivardan Fashions, Jcit, E-1/7, 2Nd Floor, East Patel Range-33, Vs. Nagar, New Delhi New Delhi Pan:Aacfv0423H (Appellant) (Respondent) Acit, Vardan Fashions, Circle-33(1) E-1/7, 2Nd Floor, East Patel Vs. New Delhi Nagar, New Delhi Pan:Aacfv0423H (Appellant) (Respondent)

For Appellant: Sh. Ajay Wadhwa, AdvFor Respondent: Sh. Vijay Verma, CIT DR
Section 142Section 40

245D(4) dated 29.07.2013 for AY 2009- 10 to 2011 -12 in case of assessee as well as one Shri Inderpal Singh Wadhawan. He relied heavily on the order wherein the assessee has himself offered 1% of total purchases in statement of facts as additional income that was enhanced by Income Tax Settlement Commission. He referred to para

MR. INDER PAL SINGH WADHAWAN,NEW DELHI vs. ACIT, NEW DELHI

In the result ground No. 2 of the appeal of the assessee is allowed

ITA 1589/DEL/2013[2008-09]Status: DisposedITAT Delhi08 Jul 2016AY 2008-09

Bench: I.C.Sudhir & Shri Prashant Maharishiinder Pal Singh Wadhawan, Jcit, E/1/7, Ii Nd Floor, East Patel Vs. Circle-33, Nagar, New Delhi New Delhi Pan: Aarps6904L (Appellant) (Respondent) Acit, Inder Pal Singh Wadhawan, Circle-33(1), Room No.1505, E/1/7, Ii Nd Floor, Vs. 15Th Floor, Dr. Shyama Prasad East Patel Nagar, New Delhi Mukherjee Civil Centre, New Delhi Pan: Aarps6904L (Appellant) (Respondent) Inder Pal Singh Wadhawan, Acit, E/1/7, Ii Nd Floor, East Patel Circle-33, Vs. Nagar, New Delhi New Delhi Pan: Aarps6904L (Appellant) (Respondent) Acit, Inder Pal Singh Wadhawan, Circle-33(1), Room No.1505, 15Th E/1/7, Ii Nd Floor, Vs. Floor, Dr. Shyama Prasad East Patel Nagar, New Delhi Mukherjee Civil Centre, Pan: Aarps6904L New Delhi (Appellant) (Respondent)

For Appellant: Sh. Ajay Wadhwa, AdvFor Respondent: Sh. Vijay Verma, CIT DR
Section 142Section 143(3)Section 68

245D(1) order, as per decision of Hon‟ble Supreme Court in the case of Brij Lal & Ors. Vs. CIT (2010) 328 ITR 477 (S.C). 18. The applicants have prayed for immunity from prosecution and imposition of penalties under various provisions of the Income Tax Act. and related sections of I.P.C. Considering the facts and circumstances of the case

ACIT, NEW DELHI vs. SH. INDERPAL SINGH WADHAWAN, NEW DELHI

In the result ground No. 2 of the appeal of the assessee is allowed

ITA 952/DEL/2013[2007-08]Status: DisposedITAT Delhi08 Jul 2016AY 2007-08

Bench: I.C.Sudhir & Shri Prashant Maharishiinder Pal Singh Wadhawan, Jcit, E/1/7, Ii Nd Floor, East Patel Vs. Circle-33, Nagar, New Delhi New Delhi Pan: Aarps6904L (Appellant) (Respondent) Acit, Inder Pal Singh Wadhawan, Circle-33(1), Room No.1505, E/1/7, Ii Nd Floor, Vs. 15Th Floor, Dr. Shyama Prasad East Patel Nagar, New Delhi Mukherjee Civil Centre, New Delhi Pan: Aarps6904L (Appellant) (Respondent) Inder Pal Singh Wadhawan, Acit, E/1/7, Ii Nd Floor, East Patel Circle-33, Vs. Nagar, New Delhi New Delhi Pan: Aarps6904L (Appellant) (Respondent) Acit, Inder Pal Singh Wadhawan, Circle-33(1), Room No.1505, 15Th E/1/7, Ii Nd Floor, Vs. Floor, Dr. Shyama Prasad East Patel Nagar, New Delhi Mukherjee Civil Centre, Pan: Aarps6904L New Delhi (Appellant) (Respondent)

For Appellant: Sh. Ajay Wadhwa, AdvFor Respondent: Sh. Vijay Verma, CIT DR
Section 142Section 143(3)Section 68

245D(1) order, as per decision of Hon‟ble Supreme Court in the case of Brij Lal & Ors. Vs. CIT (2010) 328 ITR 477 (S.C). 18. The applicants have prayed for immunity from prosecution and imposition of penalties under various provisions of the Income Tax Act. and related sections of I.P.C. Considering the facts and circumstances of the case

MR. INDER PAL SINGH WADHAWAN,NEW DELHI vs. JCIT, NEW DELHI

In the result ground No. 2 of the appeal of the assessee is allowed

ITA 1155/DEL/2013[2007-08]Status: DisposedITAT Delhi08 Jul 2016AY 2007-08

Bench: I.C.Sudhir & Shri Prashant Maharishiinder Pal Singh Wadhawan, Jcit, E/1/7, Ii Nd Floor, East Patel Vs. Circle-33, Nagar, New Delhi New Delhi Pan: Aarps6904L (Appellant) (Respondent) Acit, Inder Pal Singh Wadhawan, Circle-33(1), Room No.1505, E/1/7, Ii Nd Floor, Vs. 15Th Floor, Dr. Shyama Prasad East Patel Nagar, New Delhi Mukherjee Civil Centre, New Delhi Pan: Aarps6904L (Appellant) (Respondent) Inder Pal Singh Wadhawan, Acit, E/1/7, Ii Nd Floor, East Patel Circle-33, Vs. Nagar, New Delhi New Delhi Pan: Aarps6904L (Appellant) (Respondent) Acit, Inder Pal Singh Wadhawan, Circle-33(1), Room No.1505, 15Th E/1/7, Ii Nd Floor, Vs. Floor, Dr. Shyama Prasad East Patel Nagar, New Delhi Mukherjee Civil Centre, Pan: Aarps6904L New Delhi (Appellant) (Respondent)

For Appellant: Sh. Ajay Wadhwa, AdvFor Respondent: Sh. Vijay Verma, CIT DR
Section 142Section 143(3)Section 68

245D(1) order, as per decision of Hon‟ble Supreme Court in the case of Brij Lal & Ors. Vs. CIT (2010) 328 ITR 477 (S.C). 18. The applicants have prayed for immunity from prosecution and imposition of penalties under various provisions of the Income Tax Act. and related sections of I.P.C. Considering the facts and circumstances of the case

AGSON GLOBAL PVT. LTD,DELHI vs. ACIT CC-28, NEW DELHI

Appeals of the assessee are partly allowed and 6 appeals of the ld AO are dismissed

ITA 3741/DEL/2019[2012-13]Status: DisposedITAT Delhi31 Oct 2019AY 2012-13

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Shri Sanjay Goyal, CIT DR
Section 139Section 143Section 153A

price from these parties were added to the total income of the assessee amounting to INR 353,24,93,127/–. 12. Thus, the total income of the assessee was assessed at INR 1 610849810/– against the returned income of INR 60285750/– per order dated 30/12/2018 passed u/s 153A read with section 143 (3) of the income tax act, 1961 passed

AGSON GLOBAL PVT. LTD,DELHI vs. ACIT CC-28, NEW DELHI

Appeals of the assessee are partly allowed and 6 appeals of the ld AO are dismissed

ITA 3742/DEL/2019[2013-14]Status: DisposedITAT Delhi31 Oct 2019AY 2013-14

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Shri Sanjay Goyal, CIT DR
Section 139Section 143Section 153A

price from these parties were added to the total income of the assessee amounting to INR 353,24,93,127/–. 12. Thus, the total income of the assessee was assessed at INR 1 610849810/– against the returned income of INR 60285750/– per order dated 30/12/2018 passed u/s 153A read with section 143 (3) of the income tax act, 1961 passed

ACIT, CENTRAL CIRCLE- 28 , NEW DELHI vs. AGSON GLOBAL PVT. LTD., DELHI

Appeals of the assessee are partly allowed and 6 appeals of the ld AO are dismissed

ITA 5269/DEL/2019[2017-18]Status: DisposedITAT Delhi31 Oct 2019AY 2017-18

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Shri Sanjay Goyal, CIT DR
Section 139Section 143Section 153A

price from these parties were added to the total income of the assessee amounting to INR 353,24,93,127/–. 12. Thus, the total income of the assessee was assessed at INR 1 610849810/– against the returned income of INR 60285750/– per order dated 30/12/2018 passed u/s 153A read with section 143 (3) of the income tax act, 1961 passed

AGSON GLOBAL PVT. LTD,DELHI vs. ACIT CENTRAL CIRCLE-28, NEW DELHI

Appeals of the assessee are partly allowed and 6 appeals of the ld AO are dismissed

ITA 3743/DEL/2019[2014-15]Status: DisposedITAT Delhi31 Oct 2019AY 2014-15

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Shri Sanjay Goyal, CIT DR
Section 139Section 143Section 153A

price from these parties were added to the total income of the assessee amounting to INR 353,24,93,127/–. 12. Thus, the total income of the assessee was assessed at INR 1 610849810/– against the returned income of INR 60285750/– per order dated 30/12/2018 passed u/s 153A read with section 143 (3) of the income tax act, 1961 passed

ACIT, CENTRAL CIRCLE- 28 , NEW DELHI vs. AGSON GLOBAL PVT. LTD., DELHI

Appeals of the assessee are partly allowed and 6 appeals of the ld AO are dismissed

ITA 5267/DEL/2019[2015-16]Status: DisposedITAT Delhi31 Oct 2019AY 2015-16

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Shri Sanjay Goyal, CIT DR
Section 139Section 143Section 153A

price from these parties were added to the total income of the assessee amounting to INR 353,24,93,127/–. 12. Thus, the total income of the assessee was assessed at INR 1 610849810/– against the returned income of INR 60285750/– per order dated 30/12/2018 passed u/s 153A read with section 143 (3) of the income tax act, 1961 passed