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73 results for “transfer pricing”+ Section 80G(5)(iii)clear

Sorted by relevance

Mumbai78Delhi73Bangalore46Chandigarh25Kolkata24Chennai20Pune20Ahmedabad18Hyderabad14Lucknow11Rajkot11Jaipur7Indore7Ranchi6Cuttack5Agra3Jodhpur2Cochin2Amritsar2Nagpur1Punjab & Haryana1Visakhapatnam1

Key Topics

Section 92C60Section 80G48Section 80I45Section 143(3)45Transfer Pricing40Addition to Income39Deduction38Section 10A29Comparables/TP29

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

5); (3) Notwithstanding anything contained in sub-rule (2), rollback provision shall not be provided in respect of an international transaction for a rollback year, if,— (i) the determination of arm's length price of the said international transaction for the said year has been subject matter of an appeal before the Appellate Tribunal and the Appellate Tribunal has passed

Showing 1–20 of 73 · Page 1 of 4

Disallowance27
Section 115J19
Depreciation17

VAIDYA MANGAT RAI FOUNDATION,CHANDIGARH vs. CIT(EXEMPTION), CHANDIGARH

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

ITA 2668/DEL/2023[2023-24]Status: DisposedITAT Delhi18 Apr 2024AY 2023-24

Bench: Shri G. S. Pannu & Shri Anubhav Sharmavaidya Mangat Rai The Commissioner Of Foundation Vs. Income Tax (Exemptions) Friends Colony Chandigarh Gali No.2, Hansi Road Bhiwani. Pan-Aadtv 6078Q (Appellant) (Respondent) Assessee By Shri Tej Mohan Singh, Adv. Department By Ms. Sapna Bhattia, Cit-Dr Date Of Hearing 25/01/2024 Date Of Pronouncement 18/04/2024

Section 12A(1)(ac)Section 80(5)Section 80GSection 80G(5)

iii) of the Proviso to Section 80G(5) of the Act. This will be the harmonious interpretation. 11. If we agree with the interpretation of the ld.CIT(E), then say a trust which was formed in the year 2000, performed charitable activities since 2000, but did not applied for registration u/s.80G, the said trust will never be able to apply

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

80G of the Act in respect of donations made as part of CSR expenditure. Re: Disallowance of Deduction under section 35(2AB) amounting to Rs. 12,01,42,780/- 5. That the assessing officer erred on facts and in law in allowing weighted deduction under section 35(2AB) of the Act at Rs.100,90,68,000 as against Rs.112

M/S. HAVELLS INDIA LTD.,NEW DELHI vs. ACIT, NEW DELHI

The appeal of the assessee is partly allowed for statistical purpose

ITA 4695/DEL/2012[2008-09]Status: DisposedITAT Delhi10 Nov 2020AY 2008-09

Bench: Shri Anil Chaturvedi & Ms Suchitra Kamble(Through Video Conferencing) Vs Havells India Ltd. Acit 1, Raj Narian Marg, Ltu Civil Lines New Delhi New Delhi Aaach0351E (Respondent) (Appellant)

Section 251Section 40Section 80I

80G (Rs.22,30,000) Net loss adjusted by A.O with current year (Rs.4,67,99,123) profits On appeal, the CIT(A) confirmed the action of the Assessing Officer in adjusting the losses of earlier assessment years pertaining to Baddi Unit and Haridwar Unit while computing deduction under section 80-IC of the Act in the year under consideration

NALWA STEEL POWER LIMITED,NEW DELHI vs. ACIT, CIRCLE- 17(2), NEW DELHI

Appeal of the assessee is partly allowed for statistical purpose

ITA 7176/DEL/2017[2013-14]Status: DisposedITAT Delhi31 Dec 2018AY 2013-14

Bench: Shri N. K. Billaiya & Ms Suchitra Kamble

Section 143(3)Section 144CSection 144C(5)Section 80ISection 92D

transferred to its other business for the for the purpose of computation of profits and gains of the eligible business in terms of section 80-1 A(8) of the I.T. Act. 63. We find the Mumbai Bench of the Tribunal in the case of Deepak Fertilizers in ITA No.2116/2013 order dated 30.01.2015 for the assessment year 2010-11 while

ACIT-CIRCLE-3(1), GURGAON vs. TERADATA INDIA PRIVATE LIMITED, GURGAON

Appeal of the revenue is allowed for AY 2018-19

ITA 1430/DEL/2022[2018-19]Status: DisposedITAT Delhi13 Oct 2023AY 2018-19

Bench: Shri M. Balaganesh & Shri Yogesh Kumar Us

For Appellant: Shri Nageswar Rao, AdvFor Respondent: Shri Rajesh Kumar, CIT DR
Section 143(3)Section 37Section 80G

III-Corporate Tax Grounds 6. Denial of deduction under Section 80G 6.1. That on the facts and circumstances of the case and in law, the Learned AO has erred in disallowing the deduction of INR 27,03,104/- claimed under section 80G of the Act towards donation to various eligible institutions by incorrectly holding that that any expenses incurred

TERADATA INDIA P.LTD,GURUGRAM vs. DCIT,CIRCLE-3(1), GURUGRAM

Appeal of the revenue is allowed for AY 2018-19

ITA 1248/DEL/2022[2017-18]Status: DisposedITAT Delhi13 Oct 2023AY 2017-18

Bench: Shri M. Balaganesh & Shri Yogesh Kumar Us

For Appellant: Shri Nageswar Rao, AdvFor Respondent: Shri Rajesh Kumar, CIT DR
Section 143(3)Section 37Section 80G

III-Corporate Tax Grounds 6. Denial of deduction under Section 80G 6.1. That on the facts and circumstances of the case and in law, the Learned AO has erred in disallowing the deduction of INR 27,03,104/- claimed under section 80G of the Act towards donation to various eligible institutions by incorrectly holding that that any expenses incurred

TERADATA INDIA PVT LTD,GRUGRAM vs. DCIT CIRCLE-3(1), GURUGRAM

Appeal of the revenue is allowed for AY 2018-19

ITA 2337/DEL/2022[2018-19]Status: DisposedITAT Delhi13 Oct 2023AY 2018-19

Bench: Shri M. Balaganesh & Shri Yogesh Kumar Us

For Appellant: Shri Nageswar Rao, AdvFor Respondent: Shri Rajesh Kumar, CIT DR
Section 143(3)Section 37Section 80G

III-Corporate Tax Grounds 6. Denial of deduction under Section 80G 6.1. That on the facts and circumstances of the case and in law, the Learned AO has erred in disallowing the deduction of INR 27,03,104/- claimed under section 80G of the Act towards donation to various eligible institutions by incorrectly holding that that any expenses incurred

D.E. SHAW INDIA ADVISORY SERVICES PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

Appeals of the assessee stand partly allowed in terms of our specific observations and

ITA 1681/DEL/2015[2010-11]Status: DisposedITAT Delhi04 Sept 2017AY 2010-11

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastavaay: 2010-11 Ay: 2011-12 Ay: 2012-13 D.E. Shaw India Advisory Services Pvt. Ltd., Vs Dcit, E-20, 1St & 2Nd Floor, Circle 7(1), Main Market, Hauz Khas, New Delhi. New Delhi-110016 (Pan: Aabce6097P) (Appellant) (Respondent) Appellant By : Shri Kapil Hirani, Ca Shri Suresh Tolani, Adv. Shri Darpan Kirpalani Respondent By : Shri T.M. Shivakumar, Cit ( Dr)

For Appellant: Shri Kapil Hirani, CAFor Respondent: Shri T.M. Shivakumar, CIT ( DR)
Section 143(3)Section 144CSection 92D

80G of the Act. 6. That the learned AO/ Hon'ble DRP have erred, on the facts and in law, on the circumstances of the case and in law by alleging that the Appellant has furnished inaccurate particulars of income, thereby proposing to initiate penalty proceedings under section 271(1)(c) of the Act, the learned AO have erred

D.E. SHAW INDIA ADVISORY SERVICES PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

Appeals of the assessee stand partly allowed in terms of our specific observations and

ITA 1018/DEL/2016[2011-12]Status: DisposedITAT Delhi04 Sept 2017AY 2011-12

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastavaay: 2010-11 Ay: 2011-12 Ay: 2012-13 D.E. Shaw India Advisory Services Pvt. Ltd., Vs Dcit, E-20, 1St & 2Nd Floor, Circle 7(1), Main Market, Hauz Khas, New Delhi. New Delhi-110016 (Pan: Aabce6097P) (Appellant) (Respondent) Appellant By : Shri Kapil Hirani, Ca Shri Suresh Tolani, Adv. Shri Darpan Kirpalani Respondent By : Shri T.M. Shivakumar, Cit ( Dr)

For Appellant: Shri Kapil Hirani, CAFor Respondent: Shri T.M. Shivakumar, CIT ( DR)
Section 143(3)Section 144CSection 92D

80G of the Act. 6. That the learned AO/ Hon'ble DRP have erred, on the facts and in law, on the circumstances of the case and in law by alleging that the Appellant has furnished inaccurate particulars of income, thereby proposing to initiate penalty proceedings under section 271(1)(c) of the Act, the learned AO have erred

M/S D.E. SHAW INDIA ADVISORY SERVICES PVT. LTD.,,NEW DELHI vs. JCIT, NEW DELHI

Appeals of the assessee stand partly allowed in terms of our specific observations and

ITA 75/DEL/2017[2012-13]Status: DisposedITAT Delhi04 Sept 2017AY 2012-13

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastavaay: 2010-11 Ay: 2011-12 Ay: 2012-13 D.E. Shaw India Advisory Services Pvt. Ltd., Vs Dcit, E-20, 1St & 2Nd Floor, Circle 7(1), Main Market, Hauz Khas, New Delhi. New Delhi-110016 (Pan: Aabce6097P) (Appellant) (Respondent) Appellant By : Shri Kapil Hirani, Ca Shri Suresh Tolani, Adv. Shri Darpan Kirpalani Respondent By : Shri T.M. Shivakumar, Cit ( Dr)

For Appellant: Shri Kapil Hirani, CAFor Respondent: Shri T.M. Shivakumar, CIT ( DR)
Section 143(3)Section 144CSection 92D

80G of the Act. 6. That the learned AO/ Hon'ble DRP have erred, on the facts and in law, on the circumstances of the case and in law by alleging that the Appellant has furnished inaccurate particulars of income, thereby proposing to initiate penalty proceedings under section 271(1)(c) of the Act, the learned AO have erred

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

80G of\nthe Act. The company has declared book profit u/s 115JB at INR\n2,46,12,21,172/- and paid MAT on book profits. The return of\nincome was revised on 13.07.2016 at an income of INR\n22,56,33,190/-. The case of the assessee was taken up for scrutiny\nand a reference under section 92CA

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

80G of\nthe Act. The company has declared book profit u/s 115JB at INR\n2,46,12,21,172/- and paid MAT on book profits. The return of\nincome was revised on 13.07.2016 at an income of INR\n22,56,33,190/-. The case of the assessee was taken up for scrutiny\nand a reference under section 92CA

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

80G of\nthe Act. The company has declared book profit u/s 115JB at INR\n2,46,12,21,172/- and paid MAT on book profits. The return of\nincome was revised on 13.07.2016 at an income of INR\n22,56,33,190/-. The case of the assessee was taken up for scrutiny\nand a reference under section 92CA

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

80G of\nthe Act. The company has declared book profit u/s 115JB at INR\n2,46,12,21,172/- and paid MAT on book profits. The return of\nincome was revised on 13.07.2016 at an income of INR\n22,56,33,190/-. The case of the assessee was taken up for scrutiny\nand a reference under section 92CA

M/S DABUR INDIA LTD.,,DELHI vs. ACIT, NEW DELHI

In the result appeal of the assessee is partly allowed for statistical purposes and that of the department is dismissed

ITA 3257/DEL/2013[2006-07]Status: DisposedITAT Delhi12 Apr 2017AY 2006-07

Bench: Sh. N. K. Saini, Am & Sh. Sudhanshu Srivastava, Jm Ita No. 3257/Del/2013 : Asstt. Year : 2006-07 Dabur India Ltd., Vs Asstt. Commissioner Of Income 8/3, Asaf Ali Road, Tax, Central Circle-22, New Delhi New Delhi (Appellant) (Respondent) Pan No. Aaacd0474C

For Appellant: Sh. M. P. Rastogi, Adv. &For Respondent: Sh. Amrendra Kumar, CIT DR
Section 92Section 92(1)Section 92ASection 92BSection 92C

80G of the Act of Rs.1,59,88,250/-. The adjusted book profit u/s 115JB of the ITA Nos. 3257 & 3492/Del/2013 7 Dabur India Ltd. Act had been declared at Rs.211,42,99,386/-. The said return was processed u/s 143(1) of the Act at the returned book profit u/s 115JB of the Act. Later on, the case

DCIT, NEW DELHI vs. M/S DABUR INDIA LTD,, NEW DELHI

In the result appeal of the assessee is partly allowed for statistical purposes and that of the department is dismissed

ITA 3492/DEL/2013[2006-07]Status: DisposedITAT Delhi12 Apr 2017AY 2006-07

Bench: Sh. N. K. Saini, Am & Sh. Sudhanshu Srivastava, Jm Ita No. 3257/Del/2013 : Asstt. Year : 2006-07 Dabur India Ltd., Vs Asstt. Commissioner Of Income 8/3, Asaf Ali Road, Tax, Central Circle-22, New Delhi New Delhi (Appellant) (Respondent) Pan No. Aaacd0474C

For Appellant: Sh. M. P. Rastogi, Adv. &For Respondent: Sh. Amrendra Kumar, CIT DR
Section 92Section 92(1)Section 92ASection 92BSection 92C

80G of the Act of Rs.1,59,88,250/-. The adjusted book profit u/s 115JB of the ITA Nos. 3257 & 3492/Del/2013 7 Dabur India Ltd. Act had been declared at Rs.211,42,99,386/-. The said return was processed u/s 143(1) of the Act at the returned book profit u/s 115JB of the Act. Later on, the case

HONDA MOTORCYCLE AND SCOOTER INDIA PVT. LTD. ,GURGAON vs. ACIT, CIRCLE-1(1), GURUGRAM

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

ITA 1523/DEL/2022[2017-18]Status: DisposedITAT Delhi22 Aug 2023AY 2017-18

Bench: SHRI SHAMIM YAHYA (Accountant Member), SHRI CHALLA NAGENDRA PRASAD (Judicial Member)

For Appellant: Shri Harpreet Singh Ajmani, AdvocateFor Respondent: Shri Rajesh Kumar, CIT DR
Section 143(3)Section 92C

80G while making such donations. Re: Disallowance U/S 80JJAA - INR 15. That the AO/DRP erred on facts and in law in disallowing deduction claimed u/s 80JJAA of the Act to the extent of INR 30,00,253/-. 8 ITA No.1523/Del./2022 15.1 That the AO/DRP erred on facts and in law by applying the provision of amended section

SUMITOMO CORPORATION INDIA PVT LTD,DELHI vs. DCIT,CIRCLE-22(2), DELHI

In the result, the appeals of the assessee are partly allowed as indicated above and the stay application is dismissed as infructuous

ITA 4400/DEL/2025[2020-21]Status: DisposedITAT Delhi10 Apr 2026AY 2020-21

Bench: Shri C.N. Prasad & Shri M. Balaganesh, Accontant Member Assessment Year 2020-21 Sumitomo Corporation India Vs. Dcit Pvt. Ltd. Circle -22 (2) 501 & 502, 5Th Floor West Wing, World Mark 1, Asset No.11, Hospitality District Aerocity, New Delhi-110037 Pan No.Aabcs1887M Appellant Respondent It(Tp) Appeal No.14/Del/2025 Assessment Year 2021-22 Sumitomo Corporation India Vs. Dcit Pvt. Ltd. Circle -22 (2) 501 & 502, 5Th Floor Delhi West Wing, World Mark 1, Asset No.11, Hospitality District Aerocity, New Delhi-110037 Pan No.Aabcs1887M Appellant Respondent

Section 143(3)Section 144BSection 144C(1)Section 144C(13)Section 154Section 80GSection 92C

transfer pricing matters. The Lid. AC/TPO, in the order, also mentioned that a detailed analysis on the comparables for non-BAPA transactions, was already made in the TP order stated 30 July 2023. refer para 5 on internal page 8 of final assessment order page 14 of the appeal set). 18. Aggrieved by the final assessment order, the Appellant

MICROSOFT INDIA (R&D) PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal of the Revenue is dismissed and that of the assessee is partly allowed for statistical purposes

ITA 507/DEL/2017[2012-13]Status: DisposedITAT Delhi21 Jan 2019AY 2012-13

Bench: Shri N. K. Billaiya & Ms Suchitra Kamble

Section 143(3)

section 271 (1 )(c) of the Act. The above grounds of appeal are mutually exclusive and without prejudice to each other. The Appellant craves leave to add, amend, vary, omit or substitute, withdraw any of the aforesaid grounds of appeal at any time before or at the time of hearing of the appeal.” 3. The assessee is a private limited