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10 results for “transfer pricing”+ Section 33Bclear

Sorted by relevance

Mumbai21Ahmedabad12Delhi10Hyderabad6Bangalore3SC3Jaipur2Chandigarh2Kolkata1Pune1Chennai1Surat1

Key Topics

Section 8025Section 26322Section 80H11Section 80J8Deduction7Section 40A(2)6Section 374Section 260A4Section 10A4Transfer Pricing

MANPOWERGROUP SERVICES INDIA PRIVATE LIMITED,DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2, DELHI , JHANDEWALAN EXTENSION, NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 3585/DEL/2024[2020-2021]Status: DisposedITAT Delhi25 Sept 2025AY 2020-2021

Bench: Shri Mahavir Singh & Shri Naveen Chandra

For Appellant: Shri S.K. Agarwal, ARFor Respondent: Shri Dharm Veer Singh, CIT-DR
Section 143(3)Section 80JSection 92CSection 92D

transfer pricing order dated 29 July 2023 and the AO vide draft/final assessment order dated 30 September 2023, made certain additions/denied claims made by the Assessee and assessed the total income at Rs. 25,71,69,208/- which was upheld by the DRP. Details of additions made / claims disallowed are as under: SI. Section Adjustment/disallowance Amount (Rs.) No 1 80JJAA

3
Disallowance3
Addition to Income2

THOMSON PRESS (INDIA) LTD vs. COMMISSIONER OF INCOME TAX-II

ITA/83/2003HC Delhi09 Oct 2015
For Appellant: Mr SalilAggarwal, Mr Ravi Pratap Mall andFor Respondent: Mr Rohit Madan, Senior Standing counsel with
Section 10ASection 260ASection 263Section 80H

33B, in the circumstances and within the period specified in that section; (iii) it is not formed by the transfer to a new business of machinery or plant previously used for any purpose. Explanation : The provisions of Explanation 1 and Explanation 2 to sub-section (2) of section 80-I shall apply for the purposes of clause (iii) of this

THOMSON PRESS (INDIA) LTD. vs. COMMISSIONER OF INCOME TAX-II

ITA-83/2003HC Delhi09 Oct 2015
For Appellant: Mr SalilAggarwal, Mr Ravi Pratap Mall andFor Respondent: Mr Rohit Madan, Senior Standing counsel with
Section 10ASection 260ASection 263Section 80H

33B, in the circumstances and within the period specified in that section; (iii) it is not formed by the transfer to a new business of machinery or plant previously used for any purpose. Explanation : The provisions of Explanation 1 and Explanation 2 to sub-section (2) of section 80-I shall apply for the purposes of clause (iii) of this

THOMSON PRESS (INDIA) LTD. vs. COMMISSIONER OF INCOME TAX-II

ITA-124/2003HC Delhi09 Oct 2015
For Appellant: Mr SalilAggarwal, Mr Ravi Pratap Mall andFor Respondent: Mr Rohit Madan, Senior Standing counsel with
Section 10ASection 260ASection 263Section 80H

33B, in the circumstances and within the period specified in that section; (iii) it is not formed by the transfer to a new business of machinery or plant previously used for any purpose. Explanation : The provisions of Explanation 1 and Explanation 2 to sub-section (2) of section 80-I shall apply for the purposes of clause (iii) of this

THOMSON PRESS (INDIA) LTD vs. COMMISSIONER OF INCOME TAX-II

ITA/124/2003HC Delhi09 Oct 2015
For Appellant: Mr SalilAggarwal, Mr Ravi Pratap Mall andFor Respondent: Mr Rohit Madan, Senior Standing counsel with
Section 10ASection 260ASection 263Section 80H

33B, in the circumstances and within the period specified in that section; (iii) it is not formed by the transfer to a new business of machinery or plant previously used for any purpose. Explanation : The provisions of Explanation 1 and Explanation 2 to sub-section (2) of section 80-I shall apply for the purposes of clause (iii) of this

ACIT, CIRCLE- 4(1), GURGAON vs. LEMON TREE LAND AND DEVELOPERS PVT. LTD., NEW DELHI

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

ITA 3749/DEL/2018[2014-15]Status: DisposedITAT Delhi12 May 2023AY 2014-15

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

For Appellant: Shri Percy Pardiwala, Sr.AdvFor Respondent: Shri H.K. Choudhary, CIT- DR
Section 3Section 36Section 37Section 37(1)Section 40A(2)

Pricing assessment order of the immediately preceding A.Y 2013-14, the ld. CIT(A) held that the market rate to be taken should be 14.55% and directed the Assessing Officer accordingly. 16. Before us, the ld. counsel for the assessee had drawn our attention to the respective agreements with the two parties, namely, Tata Housing Development

LEMON TREE LAND AND DEVELOPERS PVT. LTD.,NEW DELHI vs. DCIT, CIRCLE- 2, GURGAON

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

ITA 3087/DEL/2018[2014-15]Status: DisposedITAT Delhi12 May 2023AY 2014-15

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

For Appellant: Shri Percy Pardiwala, Sr.AdvFor Respondent: Shri H.K. Choudhary, CIT- DR
Section 3Section 36Section 37Section 37(1)Section 40A(2)

Pricing assessment order of the immediately preceding A.Y 2013-14, the ld. CIT(A) held that the market rate to be taken should be 14.55% and directed the Assessing Officer accordingly. 16. Before us, the ld. counsel for the assessee had drawn our attention to the respective agreements with the two parties, namely, Tata Housing Development

COMMISSIONER OF INCOME TAX DEL-III vs. UNIPATCH RUBBER LTD

Appeal is dismissed

ITA/38/2000HC Delhi05 Jan 2015
Section 260Section 80Section 80HSection 80ISection 80J

33B, in the circumstances and within the period specified in that section : Provided further that the condition in clause (iii) shall, in relation to a small-scale industrial undertaking, apply as if the words “not being any article or thing specified in the list in the Eleventh Schedule” had been omitted. Explanation 1.—For the purposes of clause

PINE PACKAGING PRIVATE LIMITED

ITA/656/2011HC Delhi29 Mar 2012
Section 80Section 80I

33B, in the circumstances and within the period specified in that section ; (ii) it is not formed by the transfer to a new business of machinery or plant previously used for any purpose. Explanation.—The provisions of Explanations 1 and 2 to sub-section (3) of section 80-IA shall apply for the purposes of clause (ii) of this

ITO, WARD- 44(2), NEW DELHI vs. THREEPENCE CRAFT , NEW DELHI

In the result, the appeal of the assessee in ITA 2234/Del/2015\nis allowed and the appeal of the assessee in ITA 5410/Del/2019 and\nappeal of the Revenue in ITA 5995/Del/2019 are dismissed as\ninfr...

ITA 5995/DEL/2019[2011-12]Status: DisposedITAT Delhi24 Sept 2025AY 2011-12
Section 143(3)Section 263

transfer pricing adjustment. The Id.\nPCIT issued a show cause notice dated 29-05-2018\nobserving that the assessment proceedings for the A.Υ.\n2014-15 transpired that the assessee had received\nGovernment grants in the year under consideration also,\nwhich were taxable, but taken as capital receipt in the\ncomputation of total income. On the basis of a reference