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734 results for “transfer pricing”+ Unexplained Moneyclear

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Key Topics

Addition to Income83Section 153A77Section 6871Section 143(3)71Disallowance37Section 13222Unexplained Investment21Section 143(2)20Section 143

DABUR INVEST CORP,NEW DELHI vs. JCIT, RANGE-46, NEW DELHI

In the result, appeal of the assessee is partly allowed

ITA 8058/DEL/2018[2015-16]Status: DisposedITAT Delhi11 Feb 2021AY 2015-16

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi(Partially Through Video Conferencing) Dabur Invest Corp, The Joint Commissioner Of Vs. 4Th Floor, Punjabi Bhawan, 10, Income Tax , Rouse Avenue, New Delhi Range-46, Pan: Aaadfd2529G New Delhi (Appellant) (Respondent)

For Appellant: Shri M. P. Rastogi, AdvFor Respondent: Shri G. C. Srivastava, Adv
Section 143Section 4

price to be determined at the time of transfer of shares. The revenue if any will be accounted for in the year of transfer of shares.” 08. Based on above, ld AO per letter dated 15 December 2017 asked assessee to explain how the above amount of ₹ 246.85 cores is not taxable in the hands of the assessee

PERNOD RICARD INDIA PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

Showing 1–20 of 734 · Page 1 of 37

...
19
Section 69B19
Bogus Purchases19
Search & Seizure16

In the result, the recalled matter of the appeal in ITA No

ITA 911/DEL/2015[2008-09]Status: DisposedITAT Delhi10 Jul 2019AY 2008-09

Bench: Shri Amit Shukla & Shri O.P. Kant

Section 144C(13)Section 194HSection 40

money or a written agreement as suggested by the Revenue, and even if resort is had to Section 92F (v) which defines 'transaction' to include 'arrangement', 'understanding' or 'action in concert', 'whether formal or in writing', it is still incumbent on the Revenue to show the existence of an 'understanding' or an 'arrangement' or 'action in concert' between MSIL

PERNOD RICARD INDIA PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the recalled matter of the appeal in ITA No

ITA 912/DEL/2015[2009-10]Status: DisposedITAT Delhi10 Jul 2019AY 2009-10

Bench: Shri Amit Shukla & Shri O.P. Kant

Section 144C(13)Section 194HSection 40

money or a written agreement as suggested by the Revenue, and even if resort is had to Section 92F (v) which defines 'transaction' to include 'arrangement', 'understanding' or 'action in concert', 'whether formal or in writing', it is still incumbent on the Revenue to show the existence of an 'understanding' or an 'arrangement' or 'action in concert' between MSIL

PERNOD RICARD INDIA PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the recalled matter of the appeal in ITA No

ITA 914/DEL/2015[2011-12]Status: DisposedITAT Delhi10 Jul 2019AY 2011-12

Bench: Shri Amit Shukla & Shri O.P. Kant

Section 144C(13)Section 194HSection 40

money or a written agreement as suggested by the Revenue, and even if resort is had to Section 92F (v) which defines 'transaction' to include 'arrangement', 'understanding' or 'action in concert', 'whether formal or in writing', it is still incumbent on the Revenue to show the existence of an 'understanding' or an 'arrangement' or 'action in concert' between MSIL

PICO DEEPALI OVERLAYS CONSORTIUM,HARYANA vs. DCIT CENTRAL CIRCLE 17, DELHI

In the result, both the captioned appeals filed by the assessee are allowed

ITA 412/DEL/2022[2011-12]Status: DisposedITAT Delhi10 Dec 2025AY 2011-12

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2011-12 Pico Deepali Overlays Vs. Dcit, Central Circle-17, Consortium, C/O Mna & Co., Delhi Cas, Suite 444, Tower-B, Spazedge, Sector 47, Sohna Road, Gurgaon – 122 018 Pan :Aabap1880F (Appellant) (Respondent)

Section 144CSection 153ASection 92C

transfer prices. In second round, Ld. AO has merely said that there is no need to vitiate his earlier order since it has not been set aside. In fact, TPO in order dated 27.01.2021 page nos. 73 and 74 of paper books Volume I held that the issues are appearing in order of Ld. DRP regarding TP Report mentions TNMM

PICO DEEPALI OVERLAYS CONSORTIUM (BY DEEPALI DESIGNS EXHIBITS (P.) LTD.),DELHI vs. DCIT, CENTRAL CIRCLE-17, NEW DELHI

In the result, both the captioned appeals filed by the assessee are allowed

ITA 518/DEL/2022[2011-12]Status: DisposedITAT Delhi10 Dec 2025AY 2011-12

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2011-12 Pico Deepali Overlays Vs. Dcit, Central Circle-17, Consortium, C/O Mna & Co., Delhi Cas, Suite 444, Tower-B, Spazedge, Sector 47, Sohna Road, Gurgaon – 122 018 Pan :Aabap1880F (Appellant) (Respondent)

Section 144CSection 153ASection 92C

transfer prices. In second round, Ld. AO has merely said that there is no need to vitiate his earlier order since it has not been set aside. In fact, TPO in order dated 27.01.2021 page nos. 73 and 74 of paper books Volume I held that the issues are appearing in order of Ld. DRP regarding TP Report mentions TNMM

M/S. GL LITMUS EVENTS PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

Appeal of the assessee is partly allowed

ITA 2502/DEL/2015[2011-12]Status: DisposedITAT Delhi01 Jul 2019AY 2011-12

Bench: Shri Prashant Maharishi & Shri K. N. Charygl Litmus Events Pvt. Ltd, The Assistant Commissioner Vs. B-90, Second Floor, Of Income Tax Vishwakarma Colony, New Delhi Central Circle-7, New Delhi Pan: Aadcg6909N (Appellant) (Respondent)

For Appellant: Shri S. K. Tulsiyan, AdvFor Respondent: Shri Sanjay I Bara, CIT DR
Section 143Section 144CSection 153ASection 292CSection 37Section 69Section 92C

transfer pricing officer proposed an adjustment of INR 58,43,92,894/–. 17. Against the draft assessment, order the assessee-preferred objection before the learned Dispute Resolution Panel – IV, New Delhi who passed directions on 26/12/2014. Consequent to the direction of the learned dispute resolution panel, final assessment order u/s 143 (3) read with section 153A read with section 144C

ARIBA INDIA PRIVATE LIMITED,DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX, DELHI

In the result, appeal of the assessee is allowed

ITA 2705/DEL/2024[2011-12]Status: DisposedITAT Delhi27 Jan 2026AY 2011-12

Bench: SHRI YOGESH KUMAR U.S (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 143(3)Section 144CSection 144C(13)Section 144C(3)Section 92CSection 92C(3)

Transfer Pricing adjustment amounting to INR 2,071 in relation to international transaction pertaining to interest on accounts receivable: Ariba India Pvt.Ltd. vs. ACIT 4. That on the facts and in the circumstances of the case and in law, the AO/ DRP/ TPO erred in making a notional addition of INR 2,071 on account of alleged interest on perceived

DCIT, NEW DELHI vs. SH. ANIL AGGARWAL, NEW DELHI

Accordingly, they are dismissed. The cross objection of the assessee also dismissed

ITA 4667/DEL/2015[2011-12]Status: DisposedITAT Delhi30 Aug 2019AY 2011-12

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi

For Appellant: Shri Amit Goel, CAFor Respondent: Shri Samar Bhadra, CIT DR
Section 132Section 134(4)Section 143(3)Section 153ASection 6Section 6(3)Section 6(3)(ii)Section 9(1)

money from the Indian branches of Bank A based on the fixed security deposits made in other branches of Bank A in a non-taxable territory. Further the director of the assessee-company was also the main share holder of the Bank A. During the assessment proceedings, the Assessing Officer treated the entire profits of the assessee company, including interest

DCIT, NEW DELHI vs. SH. ANIL AGGARWAL, NEW DELHI

Accordingly, they are dismissed. The cross objection of the assessee also dismissed

ITA 4666/DEL/2015[2010-11]Status: DisposedITAT Delhi30 Aug 2019AY 2010-11

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi

For Appellant: Shri Amit Goel, CAFor Respondent: Shri Samar Bhadra, CIT DR
Section 132Section 134(4)Section 143(3)Section 153ASection 6Section 6(3)Section 6(3)(ii)Section 9(1)

money from the Indian branches of Bank A based on the fixed security deposits made in other branches of Bank A in a non-taxable territory. Further the director of the assessee-company was also the main share holder of the Bank A. During the assessment proceedings, the Assessing Officer treated the entire profits of the assessee company, including interest

DCIT, NEW DELHI vs. SH. ANIL AGGARWAL, NEW DELHI

Accordingly, they are dismissed. The cross objection of the assessee also dismissed

ITA 4663/DEL/2015[2007-08]Status: DisposedITAT Delhi30 Aug 2019AY 2007-08

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi

For Appellant: Shri Amit Goel, CAFor Respondent: Shri Samar Bhadra, CIT DR
Section 132Section 134(4)Section 143(3)Section 153ASection 6Section 6(3)Section 6(3)(ii)Section 9(1)

money from the Indian branches of Bank A based on the fixed security deposits made in other branches of Bank A in a non-taxable territory. Further the director of the assessee-company was also the main share holder of the Bank A. During the assessment proceedings, the Assessing Officer treated the entire profits of the assessee company, including interest

DCIT, NEW DELHI vs. SH. ANIL AGGARWAL, NEW DELHI

Accordingly, they are dismissed. The cross objection of the assessee also dismissed

ITA 4665/DEL/2015[2009-10]Status: DisposedITAT Delhi30 Aug 2019AY 2009-10

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi

For Appellant: Shri Amit Goel, CAFor Respondent: Shri Samar Bhadra, CIT DR
Section 132Section 134(4)Section 143(3)Section 153ASection 6Section 6(3)Section 6(3)(ii)Section 9(1)

money from the Indian branches of Bank A based on the fixed security deposits made in other branches of Bank A in a non-taxable territory. Further the director of the assessee-company was also the main share holder of the Bank A. During the assessment proceedings, the Assessing Officer treated the entire profits of the assessee company, including interest

DCIT, NEW DELHI vs. SH. ANIL AGGARWAL, NEW DELHI

Accordingly, they are dismissed. The cross objection of the assessee also dismissed

ITA 4662/DEL/2015[2006-07]Status: DisposedITAT Delhi30 Aug 2019AY 2006-07

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi

For Appellant: Shri Amit Goel, CAFor Respondent: Shri Samar Bhadra, CIT DR
Section 132Section 134(4)Section 143(3)Section 153ASection 6Section 6(3)Section 6(3)(ii)Section 9(1)

money from the Indian branches of Bank A based on the fixed security deposits made in other branches of Bank A in a non-taxable territory. Further the director of the assessee-company was also the main share holder of the Bank A. During the assessment proceedings, the Assessing Officer treated the entire profits of the assessee company, including interest

DCIT, NEW DELHI vs. SH. ANIL AGGARWAL, NEW DELHI

Accordingly, they are dismissed. The cross objection of the assessee also dismissed

ITA 4664/DEL/2015[2008-09]Status: DisposedITAT Delhi30 Aug 2019AY 2008-09

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi

For Appellant: Shri Amit Goel, CAFor Respondent: Shri Samar Bhadra, CIT DR
Section 132Section 134(4)Section 143(3)Section 153ASection 6Section 6(3)Section 6(3)(ii)Section 9(1)

money from the Indian branches of Bank A based on the fixed security deposits made in other branches of Bank A in a non-taxable territory. Further the director of the assessee-company was also the main share holder of the Bank A. During the assessment proceedings, the Assessing Officer treated the entire profits of the assessee company, including interest

DCIT, NEW DELHI vs. SH. ANIL AGGARWAL, NEW DELHI

Accordingly, they are dismissed. The cross objection of the assessee also dismissed

ITA 4668/DEL/2015[2012-13]Status: DisposedITAT Delhi30 Aug 2019AY 2012-13

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi

For Appellant: Shri Amit Goel, CAFor Respondent: Shri Samar Bhadra, CIT DR
Section 132Section 134(4)Section 143(3)Section 153ASection 6Section 6(3)Section 6(3)(ii)Section 9(1)

money from the Indian branches of Bank A based on the fixed security deposits made in other branches of Bank A in a non-taxable territory. Further the director of the assessee-company was also the main share holder of the Bank A. During the assessment proceedings, the Assessing Officer treated the entire profits of the assessee company, including interest

MR. MOHAN SAMBHAJI JAGTHAP,GURGAON vs. ACIT, NEW DELHI

In the result, the appeals of the assessee are partly allowed and the appeal of the Revenue is dismissed

ITA 5460/DEL/2016[2002-03]Status: DisposedITAT Delhi30 Jun 2022AY 2002-03

Bench: Sh. Aakash Deep Jaindr. B. R. R. Kumar

For Appellant: Sh. Mukesh Rana, AdvFor Respondent: Sh. Bhavnesh Kulsheshtha, CIT DR
Section 132Section 292CSection 68

unexplained. All the documents related to the remittance of this money have been found in the possession of the assessee. The assessee himself has been instrumental in transferring the money from Kazakhstan to the account of Mrs. Pooja Sharma. All the documents evidencing the operation of routing of monies have been found and seized. Hence, keeping in view the entire

MR. MOHAN SAMBHAJI JAGTHAP,GURGAON vs. ACIT, NEW DELHI

In the result, the appeals of the assessee are partly allowed and the appeal of the Revenue is dismissed

ITA 5462/DEL/2016[2007-08]Status: DisposedITAT Delhi30 Jun 2022AY 2007-08

Bench: Sh. Aakash Deep Jaindr. B. R. R. Kumar

For Appellant: Sh. Mukesh Rana, AdvFor Respondent: Sh. Bhavnesh Kulsheshtha, CIT DR
Section 132Section 292CSection 68

unexplained. All the documents related to the remittance of this money have been found in the possession of the assessee. The assessee himself has been instrumental in transferring the money from Kazakhstan to the account of Mrs. Pooja Sharma. All the documents evidencing the operation of routing of monies have been found and seized. Hence, keeping in view the entire

MR. MOHAN SAMBHAJI JAGTHAP,GURGAON vs. ACIT, NEW DELHI

In the result, the appeals of the assessee are partly allowed and the appeal of the Revenue is dismissed

ITA 5461/DEL/2016[2006-07]Status: DisposedITAT Delhi30 Jun 2022AY 2006-07

Bench: Sh. Aakash Deep Jaindr. B. R. R. Kumar

For Appellant: Sh. Mukesh Rana, AdvFor Respondent: Sh. Bhavnesh Kulsheshtha, CIT DR
Section 132Section 292CSection 68

unexplained. All the documents related to the remittance of this money have been found in the possession of the assessee. The assessee himself has been instrumental in transferring the money from Kazakhstan to the account of Mrs. Pooja Sharma. All the documents evidencing the operation of routing of monies have been found and seized. Hence, keeping in view the entire

ACIT, NEW DELHI vs. SH. MOHAN SAMBHAJI JAGTHAP, GURGAON

In the result, the appeals of the assessee are partly allowed and the appeal of the Revenue is dismissed

ITA 6026/DEL/2016[2007-08]Status: DisposedITAT Delhi30 Jun 2022AY 2007-08

Bench: Sh. Aakash Deep Jaindr. B. R. R. Kumar

For Appellant: Sh. Mukesh Rana, AdvFor Respondent: Sh. Bhavnesh Kulsheshtha, CIT DR
Section 132Section 292CSection 68

unexplained. All the documents related to the remittance of this money have been found in the possession of the assessee. The assessee himself has been instrumental in transferring the money from Kazakhstan to the account of Mrs. Pooja Sharma. All the documents evidencing the operation of routing of monies have been found and seized. Hence, keeping in view the entire

KUNDAN RICE MILLS LTD.,DELHI vs. ACIT, KARNAL

In the result, all the appeals of the department as well as the cross objections of the assessee are allowed for statistical purposes

ITA 31/DEL/2015[2005-06]Status: DisposedITAT Delhi30 Nov 2015AY 2005-06

Bench: Shri N.K.Saini & Shri C.M. Garg

For Appellant: Shri Ved Jain, CAFor Respondent: Shri Gajanand Meena, CIT-DR
Section 133ASection 145Section 153A

unexplained cash credits u/s 68 of the Act. In response, the explanation of the assessee was that since the sales made to those two parties were also credited in the books of accounts, therefore, no addition should have been made on account of cash credits. The AO although accepted the above contention of the assessee but held that the sales