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65 results for “transfer pricing”+ Section 80G(5)(vi)clear

Sorted by relevance

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Key Topics

Section 80G53Section 80I52Section 92C52Section 143(3)40Deduction38Addition to Income36Transfer Pricing34Section 10A29Disallowance29

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

80G of the Act was claimed. Vide note no.13 to the computation of the income such contribution was claimed as deduction u/s 37 of the Act. Ld. AO disallowed it holding that it was not incurred for the purposes of the business and alternatively as no tax has been deducted it was disallowable

Showing 1–20 of 65 · Page 1 of 4

Comparables/TP23
Section 115J19
TP Method13

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

5,72,619 Other additions/disallowances Addition w.r.t. to expenditure incurred on in-house 12,01,42,780 scientific research under section 35(2AB) of the Act Disallowance w.r.t. deduction claimed under section 638,13,601 80G of the Act on account of donations given Addition w.r.t. difference in Duty Drawback 2,18,481 10. On receipt of the draft order

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)

vi) an entity making fresh application for approval under clause (23C) of section 10, for registration under section 12AA, for approval under section 80G shall be provisionally approved or registered for three years on the basis of application without detailed enquiry even in the cases where activities of the entity are yet to begin and then it has to apply

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

vi) by not appreciating that a machinery provision which enables the assessee to avail of a deduction u/s 80IA , conferred by substantive provision in the income tax Act is required to be construed liberally. (vii) by not affording an opportunity for purporting the rates to be adopted. (B)The Hon'ble DRP and Ld. TPO/ A.O. 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 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

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

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

AMWAY INDIA ENTERPRISES PRIVATE LIMITED,NEW DELHI vs. DCIT, CIRCLE 1(1), DELHI / NFAC, DELHI

Appeal of the assessee is allowed

ITA 5912/DEL/2024[2021-22]Status: DisposedITAT Delhi20 Nov 2025AY 2021-22

Bench: Shri Sudhir Pareek & Shri Manish Agarwalamway India Enterprises Private Dcit, Limited, Circle-1(1), Ground Floor, Elegance Tower, Vs. Delhi/Nfac. Plot No.8, Non Hierarchical Commercial, Jasola, Delhi-110025. Pan-Aaaca5603Q (Appellant) (Respondent)

Section 143(1)(a)Section 143(2)Section 143(3)Section 80GSection 92C

5. Ground of appeal No.1 is general in nature and needs no adjudication. 6. In Ground of appeal No. 2 assessee has challenged the various additions/disallowance made on account of transfer price adjustment and donation and further challenged the income computed in the order passed u/s 143(1) of the Amway India Enterprises Private Limited vs. DCIT Act where

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

VI-A of the Act, which is otherwise eligible. 6.4. That on the facts and circumstances of the case and in law, the Learned AO has erred in not appreciating the intent of the legislature that the disallowance of deduction under Section 80G of the Act by way of CSR contribution was limited to clauses (iiihk) and (iiihl) of section

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

VI-A of the Act, which is otherwise eligible. 6.4. That on the facts and circumstances of the case and in law, the Learned AO has erred in not appreciating the intent of the legislature that the disallowance of deduction under Section 80G of the Act by way of CSR contribution was limited to clauses (iiihk) and (iiihl) of section

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

VI-A of the Act, which is otherwise eligible. 6.4. That on the facts and circumstances of the case and in law, the Learned AO has erred in not appreciating the intent of the legislature that the disallowance of deduction under Section 80G of the Act by way of CSR contribution was limited to clauses (iiihk) and (iiihl) of section

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 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

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

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

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

SAMSUNG INDIA ELECTRONICS PRIVATE LIMITED,NEW DELHI vs. ITO, DELHI

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

ITA 3724/DEL/2024[2020-21]Status: DisposedITAT Delhi25 Sept 2025AY 2020-21

Bench: Shri Challa Nagendram Prasad & Shri Naveen Chandra

For Appellant: Shri Himanshu Sinha, AdvFor Respondent: Shri Dharam Veer Singh, CIT-DR
Section 143(3)Section 80G

transfer pricing are dismissed as withdrawn. 5. Ground Nos. 28 to 32 relate to disallowance on account of salary paid to expatriates. 6. At the very outset, the ld. counsel for the assessee submitted that this issue is squarely covered in favour of the assessee and against the Revenue by the decision of the co-ordinate bench in assessee

SAMSUNG INDIA ELECTRONICS PRIVATE LIMITED,NEW DELHI vs. DCIT, CIRCLE-22(2), DELHI

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

ITA 5256/DEL/2024[2021-22]Status: DisposedITAT Delhi25 Sept 2025AY 2021-22

Bench: Shri Challa Nagendram Prasad & Shri Naveen Chandra

For Appellant: Shri Himanshu Sinha, AdvFor Respondent: Shri Dharam Veer Singh, CIT-DR
Section 143(3)Section 80G

transfer pricing are dismissed as withdrawn. 5. Ground Nos. 28 to 32 relate to disallowance on account of salary paid to expatriates. 6. At the very outset, the ld. counsel for the assessee submitted that this issue is squarely covered in favour of the assessee and against the Revenue by the decision of the co-ordinate bench in assessee