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25 results for “transfer pricing”+ Section 80P(4)clear

Sorted by relevance

Bangalore51Delhi25Visakhapatnam23Mumbai15Kolkata15Surat8Pune7Chennai7Telangana4Nagpur4Karnataka3Hyderabad3Lucknow2SC1Ahmedabad1Indore1

Key Topics

Section 14A31Section 26324Section 80H14Deduction14Addition to Income12Section 143(3)11Disallowance11Section 108Section 45(2)8Section 260A

NTT DATA GLOBAL DELIVERY SERVICES LTD.,BANGALORE vs. DCIT, NEW DELHI

The appeal of the assessee is partly allowed

ITA 5196/DEL/2014[2009-10]Status: DisposedITAT Delhi20 Dec 2018AY 2009-10

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishintt Data Global Delivery Vs. Dcit, Services Ltd, Circle-13(1), No. 17, South End Road, New Delhi Bangalore Pan: Aabck7777J (Appellant) (Respondent)

For Appellant: Shri Purushottam, AdvFor Respondent: Shri Amit Katoch, CIT DR
Section 10Section 10ASection 143

transfer pricing adjustment also during the course of assessment proceedings. Consequently, the returned income of the assessee of INR 30 170 320720/– was assessed at INR 70 21138145/– wide order under section 143 (3) of the income tax act wide order dated 28/3/2013. 4. The order of the learned AO was challenged before the learned CIT – A. He passed

Showing 1–20 of 25 · Page 1 of 2

7
Section 10A7
Exemption4

MUFG BANK LTD,NEW DELHI vs. ACIT (INTERNATIONAL TAXATION) CIRCLE-2(2)(1), NEW DELHI

In the result appeal of the assessee is partly allowed

ITA 7895/DEL/2019[2015-16]Status: DisposedITAT Delhi16 Oct 2020AY 2015-16

Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing) Mufg Bank Ltd, Vs. Acit (International Taxation), 5Th Floor, Worldmark 2, Asset 8, Circle-2(2)(1), Aerocity, Nh-8, New Delhi New Delhi Pan: Aabct3880D (Appellant) (Respondent)

For Appellant: Shri Nishant Thakkar, AdvFor Respondent: Shr Surender Pal, CIT DR
Section 143(3)Section 14ASection 244ASection 37(1)Section 44C

transfer pricing addition on account of the corporate guarantee commission of ₹ 103,485,509/– iii. disallowance u/s 14 A of the income tax act of ₹ 22,521,366/– iv. charge of interest on external commercial borrowing of ₹ 518,00,31,066 to be taxed at the rate of 10% as per the provisions of article 11 of the Double Taxation

M/S 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

4) shall also apply in computing the total income of the assessee for the assessment year immediately succeeding the last of the relevant assessment years and any subsequent assessment year. (6) The provisions of sub-section (8) and sub-section (9) of section 80-I shall, so far as may be, apply in relation to the industrial undertaking referred

M/S 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

4) shall also apply in computing the total income of the assessee for the assessment year immediately succeeding the last of the relevant assessment years and any subsequent assessment year. (6) The provisions of sub-section (8) and sub-section (9) of section 80-I shall, so far as may be, apply in relation to the industrial undertaking referred

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

4) shall also apply in computing the total income of the assessee for the assessment year immediately succeeding the last of the relevant assessment years and any subsequent assessment year. (6) The provisions of sub-section (8) and sub-section (9) of section 80-I shall, so far as may be, apply in relation to the industrial undertaking referred

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

4) shall also apply in computing the total income of the assessee for the assessment year immediately succeeding the last of the relevant assessment years and any subsequent assessment year. (6) The provisions of sub-section (8) and sub-section (9) of section 80-I shall, so far as may be, apply in relation to the industrial undertaking referred

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

4) shall also apply in computing the total income of the assessee for the assessment year immediately succeeding the last of the relevant assessment years and any subsequent assessment year. (6) The provisions of sub-section (8) and sub-section (9) of section 80-I shall, so far as may be, apply in relation to the industrial undertaking referred

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

4) shall also apply in computing the total income of the assessee for the assessment year immediately succeeding the last of the relevant assessment years and any subsequent assessment year. (6) The provisions of sub-section (8) and sub-section (9) of section 80-I shall, so far as may be, apply in relation to the industrial undertaking referred

GREAT EASTERN EXPORTS vs. ASSISTANT COMMISSIONER OF INCOME TAX

ITA/267/2008HC Delhi29 Nov 2010

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

Section 80Section 80HSection 80I

transfer, in either case, had been made at the market value of such goods or services as on that date. Explanation.--For the purposes of this sub-section, the expression “market value”,-- (i) in relation to any goods or services sold or supplied, means the price that such goods or services would fetch if these were sold by the undertaking

CAIRN UK HOLDING LTD.,AHMEDABAD vs. DCIT (INTERNATIONAL TAXATION), NEW DELHI

In the result ground No. 5 of the appeal of the assessee is allowed

ITA 1669/DEL/2016[2007-08]Status: DisposedITAT Delhi09 Mar 2017AY 2007-08

Bench: Shri H. S. Sidhu & Shri Prashant Maharishi

For Appellant: Shri Percy Pardiwala Sr. AdvFor Respondent: Shri Sanjay Puri CIT
Section 143(3)Section 144

Section 148, the reassessment had been initiated without any basis and information and as such the same is liable to be quashed. Furthermore, as noted above, no new documents were discovered by the survey proceedings in January 2014 - all of the documents in question had been in the hands of the government in 2006. The reason that

M/S THE ORIENTAL INSSURANCE CO.LTD.,,NEW DELHI vs. DCIT, NEW DELHI

ITA 200/DEL/2016[2011-12]Status: DisposedITAT Delhi22 Nov 2022AY 2011-12

Bench: Shri Anil Chaturvedi & Shri Anubhav Sharmam/S. The Oriental Insurance Co. Ltd, Vs. The Dcit, A 25/27, Asaf Ali Road, Ltu, New Delhi New Delhi-110002 (Appellant) (Respondent) Pan: Aaact0627R

For Appellant: Shri Tarandeep Singh, AdvFor Respondent: Ms. Sarita Kumari, CIT DR
Section 10(38)Section 115Section 115JSection 143(1)Section 143(2)Section 143(3)Section 14ASection 28Section 44

4) states that an insurer "shall not invest or keep invested any part of his assets in the shares of any one banking company or investment company to the extent of more than (a) 10% of his assets, or (b) 2% of the subscribed share capital and debentures of the banking company or investment company concerned, whichever is less

THE ORIENTAL INSURANCE CO. LTD.,NEW DELHI vs. DCIT, CIRCLE- 1, LTU, NEW DELHI

ITA 1952/DEL/2018[2013-14]Status: DisposedITAT Delhi29 May 2023AY 2013-14

Bench: Sh. Anil Chaturvedi & Sh.Anubhav Sharmaita No. 1952/Del/2018, A.Y. 2013-14 M/S. The Oriental Insurance Co. Vs. Dcit, Ltd. Circle-1, Ltu, A-25/27, Asaf Ali Road, New Delhi New Delhi- 110002 Pan :Aaact0627R

Section 10(38)Section 111ASection 115JSection 143(3)Section 14ASection 32

4) states that an insurer "shall not invest or keep invested any part of his assets in the shares of any one banking company or investment company to the extent of more than (a) 10% of his assets, or (b) 2% of the subscribed share capital and debentures of the banking company or investment company concerned, whichever is less

DCIT, CIRCLE- 1, LTU, NEW DELHI vs. THE ORIENTAL INSURANCE CO. LTD., NEW DELHI

ITA 1750/DEL/2018[2013-14]Status: DisposedITAT Delhi29 May 2023AY 2013-14

Bench: Sh. Anil Chaturvedi & Sh.Anubhav Sharmaita No. 1952/Del/2018, A.Y. 2013-14 M/S. The Oriental Insurance Co. Vs. Dcit, Ltd. Circle-1, Ltu, A-25/27, Asaf Ali Road, New Delhi New Delhi- 110002 Pan :Aaact0627R

Section 10(38)Section 111ASection 115JSection 143(3)Section 14ASection 32

4) states that an insurer "shall not invest or keep invested any part of his assets in the shares of any one banking company or investment company to the extent of more than (a) 10% of his assets, or (b) 2% of the subscribed share capital and debentures of the banking company or investment company concerned, whichever is less

M/S. RELIGARE SECURITIES LTD.,NEW DELHI vs. ACIT, NEW DELHI

The appeal of the assessee stands allowed in terms of our directions contained in the preceding

ITA 2282/DEL/2013[2008-09]Status: DisposedITAT Delhi13 Dec 2019AY 2008-09

Bench: Shri N.K. Billaiya & Shri Sudhanshu Srivastavaasstt. Year: 2008-09

For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Smt. Sulekha Verma, CIT(DR)
Section 143(1)Section 14ASection 28Section 36Section 36(1)(ii)Section 37(1)

price of Rs. 150 per piece, whether the loss of Rs. 50 can be said to be allowable where the assessee accounts for only Rs. 100 as sales and not at Rs. 150. In such a situation, the loss will be only a notional loss or the loss of possible benefit but not the loss or liability incurred

ACIT, NEW DELHI vs. NATIONAL AGRICULTURAL COOPERATIVE MARKETING FEDERATION OF INDIA, NEW DELHI

ITA 4108/DEL/2015[2010-11]Status: DisposedITAT Delhi24 Aug 2022AY 2010-11

Bench: Shri N.K. Billaiya & Shri Anubhav Sharma

For Appellant: Shri Hiren Mehta, CAFor Respondent: Shri Ishtiyaque Ahmed, Sr. DR
Section 10Section 139(5)Section 14ASection 194HSection 40Section 41(1)Section 43Section 43(5)(d)Section 43BSection 72

80P(2)(d) of the Act which contained details of dividend received from co-operative societies claimed to be exempt under this section. 14. Invoking provisions of section 14A of the Act and applying Rule 8D of the Rules, the Assessing Officer computed the disallowance at Rs. 1,05,69,459/-. We find that this quarrel was before

COMMISSIONER OF INCOME TAX vs. TALANGANG COOP GROUP HOUSING SOCIETY LTD

The appeal stands dismissed in limine

ITA - 744 / 2010HC Delhi01 Jul 2010
Section 234Section 260ASection 271(1)(c)Section 80P

price is to be treated 2010:DHC:3194-DB as income as short term capital gains of the assessee for the assessment year 2001- 2002. The amount spent on purchase of dustbins for the garden maintenance was treated as capital nature and assessed as the same. As far as the receipt of interest is concerned, the assessing officer came

DCIT, NEW DELHI vs. M/S. R.J. CORP LTD., NEW DELHI

In the result, the appeal of the assessee on this ground is allowed

ITA 5310/DEL/2015[2011-12]Status: DisposedITAT Delhi25 Aug 2022AY 2011-12

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Sh. Rajat Jain, CA&For Respondent: Sh. T. Kipgen, CIT DR
Section 14ASection 45(2)

80P(2)(a)(i) of the Act but would also be applicable to all banks/commercial banks, to which Banking Regulation Act, 1949 applies. 38. From this, Punjab and Haryana High Court pointed out that this circular carves out a distinction between 'stock-in-trade' and 'investment' and provides that if the motive behind purchase and sale of shares

M/S. RJ CORP LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeal of the assessee on this ground is allowed

ITA 4971/DEL/2015[2011-12]Status: DisposedITAT Delhi25 Aug 2022AY 2011-12

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Sh. Rajat Jain, CA&For Respondent: Sh. T. Kipgen, CIT DR
Section 14ASection 45(2)

80P(2)(a)(i) of the Act but would also be applicable to all banks/commercial banks, to which Banking Regulation Act, 1949 applies. 38. From this, Punjab and Haryana High Court pointed out that this circular carves out a distinction between 'stock-in-trade' and 'investment' and provides that if the motive behind purchase and sale of shares

DCIT, NEW DELHI vs. M/S. R.J. CORP LTD., NEW DELHI

In the result, the appeal of the assessee on this ground is allowed

ITA 5311/DEL/2015[2012-13]Status: DisposedITAT Delhi25 Aug 2022AY 2012-13

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Sh. Rajat Jain, CA&For Respondent: Sh. T. Kipgen, CIT DR
Section 14ASection 45(2)

80P(2)(a)(i) of the Act but would also be applicable to all banks/commercial banks, to which Banking Regulation Act, 1949 applies. 38. From this, Punjab and Haryana High Court pointed out that this circular carves out a distinction between 'stock-in-trade' and 'investment' and provides that if the motive behind purchase and sale of shares

M/S. RJ CORP LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeal of the assessee on this ground is allowed

ITA 4972/DEL/2015[2012-13]Status: DisposedITAT Delhi25 Aug 2022AY 2012-13

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Sh. Rajat Jain, CA&For Respondent: Sh. T. Kipgen, CIT DR
Section 14ASection 45(2)

80P(2)(a)(i) of the Act but would also be applicable to all banks/commercial banks, to which Banking Regulation Act, 1949 applies. 38. From this, Punjab and Haryana High Court pointed out that this circular carves out a distinction between 'stock-in-trade' and 'investment' and provides that if the motive behind purchase and sale of shares