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37 results for “transfer pricing”+ Business Incomeclear

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Key Topics

Section 92B34Section 143(3)20Section 6817Addition to Income15Section 143(2)11Section 26310Section 43B8Section 92C7Transfer Pricing

MAHALAXMI CONTINENTAL LIMITED,GUWAHATI vs. INCOME TAX OFFICER (DCIT/ACIT CIR-1), GUWAHATI

In the result, both the appeals of the assessee are allowed

ITA 53/GTY/2025[2015-16]Status: DisposedITAT Guwahati13 Mar 2026AY 2015-16

Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumar

Section 250Section 92B

income of the assessee. 6. In the appellate proceedings, the ld. CIT(A) noted that the Transfer Pricing Officer has followed Transactional Net Margin Method (TNMM) as most appropriate method and rightly made the adjustments by selecting suitable comparables considering the size and nature of business

MAHALAXMI CONTINENTAL LIMITED,GUWAHATI vs. INCOME TAX OFFICER (DCIT/ACIT CIR-1), GUWAHATI

In the result, both the appeals of the assessee are allowed

ITA 54/GTY/2025[2016-17]Status: DisposedITAT Guwahati

Showing 1–20 of 37 · Page 1 of 2

7
Section 2506
Exemption5
Disallowance5
13 Mar 2026
AY 2016-17

Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumar

Section 250Section 92B

income of the assessee. 6. In the appellate proceedings, the ld. CIT(A) noted that the Transfer Pricing Officer has followed Transactional Net Margin Method (TNMM) as most appropriate method and rightly made the adjustments by selecting suitable comparables considering the size and nature of business

GREENPLY INDUSTRIES LIMITED,TINSUKIA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-TINSUKIA, TINSUKIA

In the result, the appeal of the assessee for A

ITA 232/GTY/2019[2014-15]Status: DisposedITAT Guwahati21 Jun 2022AY 2014-15

Bench: Shri A.T. Varkey & Shri Manish Borad

Section 115JSection 143(2)Section 80ISection 92C

Transfer Pricing Officer (in short ‘TPO’) within the meaning of section 92CA of the Income Tax Act after necessary approval. Subsequently ld. TPO passed the order under section 92CA of the Act on 27.10.2017 suggesting the upward adjustment of Rs.43,67,295/- for Corporate Guarantee given by the assessee to its Associated Enterprises (AE) and downward adjustment in respect

ACIT, CIRCLE - TINSUKIA , TINSUKIA vs. M/S. GREENPLY INDUSTRIES LTD., TINSUKIA

In the result, the appeal of the assessee for A

ITA 359/GTY/2019[2014-15]Status: DisposedITAT Guwahati21 Jun 2022AY 2014-15

Bench: Shri A.T. Varkey & Shri Manish Borad

Section 115JSection 143(2)Section 80ISection 92C

Transfer Pricing Officer (in short ‘TPO’) within the meaning of section 92CA of the Income Tax Act after necessary approval. Subsequently ld. TPO passed the order under section 92CA of the Act on 27.10.2017 suggesting the upward adjustment of Rs.43,67,295/- for Corporate Guarantee given by the assessee to its Associated Enterprises (AE) and downward adjustment in respect

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, DIBRUGARH vs. GREENPLY INDUSTRIES LIMITED, KOLKATA

In the result, the appeal of the Revenue is dismissed

ITA 140/GTY/2024[2013-14]Status: DisposedITAT Guwahati15 Dec 2025AY 2013-14

Bench: Shri Rajesh Kumar, Am & Shrimanomohan Das, Jm Greenply Industries Ltd Acit, Circle-1 Madgul Lounge, 5 Th Floor, 23 Aaykar Bhawan, Milan Nagar, Chetiacental Road, Kolkata- Vs. Dibrugarh-786001, Assam 700027, West Bengal (Appellant) (Respondent) Pan No. Aaacg7284R Assessee By : Shri Ashok Tulsyan, Ar Revenue By : Shri Sanjay Jha, Dr Date Of Hearing: 02.12.2025 Date Of Pronouncement: 15.12.2025

For Appellant: Shri Ashok Tulsyan, ARFor Respondent: Shri Sanjay Jha, DR
Section 115J

Transfer Pricing Guidelines 2010 supports this view in para 7.13 where it is explained that where higher credit rating of Associated Enterprise is due to a guarantee by another group member, such association positively enhances the profit making potential of that Associated Enterprise. We, therefore, find ourselves in agreement with the contention of the Id. D.R. that there

SHREE PRAKSH SINGH,GURGAON vs. INCOME TAX OFFICER, WARD-1, DIGBOI

In the result, the appeal of the assessee is allowed

ITA 14/GTY/2019[2012-13]Status: DisposedITAT Guwahati09 Oct 2020AY 2012-13

Bench: Shri A. T. Varkey, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.14/Gau/2019 ("नधा"रणवष" / Assessment Year:2012-13)

For Appellant: Shri S. P. Bhati, A.RFor Respondent: Shri Amitava Sen, JCIT, Sr. D.R
Section 143(2)Section 143(3)Section 147Section 148Section 50CSection 50C(1)

transfer of the leasehold and encumbered property is not covered under the provisions of section 50C. 3. For that the learned Assessing Officer has grossly erred in facts and in law in making an addition of Rs. 5,50,17,042/- in complete disregard to the actual sale price realized by the assessee without any evidence of the receipt

SHRI BIMAL PAUL,SILCHAR vs. INCOME TAX OFFICER, WARD-1, SILCHAR

In the result, both the appeals of the assessee are dismissed

ITA 211/GTY/2014[2010-11]Status: DisposedITAT Guwahati06 Oct 2023AY 2010-11

Bench: Shri Rajpal Yadav & Shri Girish Agrawalassessment Year: 2010-11 & Assessment Year: 2011-12

For Appellant: N o n eFor Respondent: Shri Arun Bhowmick, JCIT
Section 142Section 143(2)Section 143(3)Section 153(1)

Transfer Pricing Officer during the course of assessment/reassessment proceedings. These time limits are either from the end of the financial year in which the notice for initiation of the proceedings was served or from the end of the assessment year to which the proceedings relate. It is proposed to amend the aforesaid sections, i.e., 153 and 153B

SHRI BIMAL PAUL,SILCHAR vs. INCOME TAX OFFICER, WARD-1, SILCHAR

In the result, both the appeals of the assessee are dismissed

ITA 8/GTY/2016[2011-12]Status: DisposedITAT Guwahati06 Oct 2023AY 2011-12

Bench: Shri Rajpal Yadav & Shri Girish Agrawalassessment Year: 2010-11 & Assessment Year: 2011-12

For Appellant: N o n eFor Respondent: Shri Arun Bhowmick, JCIT
Section 142Section 143(2)Section 143(3)Section 153(1)

Transfer Pricing Officer during the course of assessment/reassessment proceedings. These time limits are either from the end of the financial year in which the notice for initiation of the proceedings was served or from the end of the assessment year to which the proceedings relate. It is proposed to amend the aforesaid sections, i.e., 153 and 153B

SAROJ DEVI SAND,SILCHAR vs. INCOEM TAX OFFICER, WARD-3, SILCHAR

In the result, both the appeals filed by the assessees in ITA

ITA 51/GTY/2020[2015-16]Status: DisposedITAT Guwahati23 Dec 2022AY 2015-16

Bench: Sri Rajpal Yadav(Kz) & Dr. Manish Borad

Section 143(3)Section 250Section 68

transfer of Shares in M/s. Pine Animations Ltd and shares of M/s. Jackson Investments Ltd of Rs. 50,40,340/- 12. That the Authorities erred in not providing complete details to the assessee before completing the assessment. 13. The appellant denies the liabilities for interest u/s 234A, 234B and 234C of the Act. Further prays that the interest

INDER CHAND SAND,SILCHAR vs. INCOME TAX OFFICER, WARD-2, SILCHAR

In the result, both the appeals filed by the assessees in ITA

ITA 49/GTY/2020[2015-16]Status: DisposedITAT Guwahati23 Dec 2022AY 2015-16

Bench: Sri Rajpal Yadav(Kz) & Dr. Manish Borad

Section 143(3)Section 250Section 68

transfer of Shares in M/s. Pine Animations Ltd and shares of M/s. Jackson Investments Ltd of Rs. 50,40,340/- 12. That the Authorities erred in not providing complete details to the assessee before completing the assessment. 13. The appellant denies the liabilities for interest u/s 234A, 234B and 234C of the Act. Further prays that the interest

M/S. BHARTIA-SMSIL(JV),GUWAHATI vs. INCOME TAX OFFICER, WARD-3(1), GUWAHATI

In the result, the appeal of the assessee is allowed

ITA 117/GTY/2019[2014-15]Status: DisposedITAT Guwahati17 Jun 2020AY 2014-15

Bench: Shri A. T. Varkey, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.117/Gau/2019 ("नधा"रणवष" / Assessment Year:2014-15)

For Appellant: Shri Sanjay Modi, FCAFor Respondent: Shri M.K. Dal, Addl. CIT, Sr. Dr
Section 143(3)Section 263Section 3Section 92BSection 92C

Transfer Pricing Officer by the Assessing officer after obtaining the approval of PCIT as per 92CA of the Act. In this view of the matter the benchmarking of the domestic transaction undertaken with the specified domestic parties for the purpose of determining the Arms Length Price was not done in this case. In the above conspectus, the order passed

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, GUWAHATI vs. ASSAM POWER DISTRIBUTION COMPANY LIMITED, GUWAHATI

In the result, the appeal filed by the Revenue is dismissed and the Cross Objection filed by the assessee is partly allowed

ITA 256/GTY/2019[2012-13]Status: DisposedITAT Guwahati30 Aug 2022AY 2012-13

Bench: Sri Manish Borad & Sri Sonjoy Sarma

Section 142(1)Section 143(2)Section 250Section 40Section 43B

transferred to Pension Trust as per GOA notification) Page 4 of 13 I.T.A. No.: 256/Gau/2019 C.O. No.: 13/Gau/2019 Assessment Year: 2012-13 M/s. Assam Power Distribution Company Ltd. Be that as it may, I have not found any adverse comments of the CAG in this behalf. In item 2.8 of the Notes on Account of the 9th Annual Report

SHIVANI ISPAT AND ROLLING MILL (P) LTD.,BYRNIHAT vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-SHILLONG, SHILLONG

In the result, the appeal of the assessee is allowed

ITA 227/GTY/2019[2014-15]Status: DisposedITAT Guwahati31 Jul 2020AY 2014-15

Bench: Shri A. T. Varkey, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.227/Gau/2019 ("नधा"रणवष" / Assessment Year:2014-15) Shivani Ispatand Rolling Mill Vs. Acit, Circle-Shillong (P) Ltd. 13Th Mile, Tamulkuchi, Byrnihat, G.S. Road, Ri-Bhoi, Meghalaya "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aafcs 3465 B (Appellant) .. (Respondent) Appellant By :Shri J.P. Gupta, Fca Respondent By :Shri T. Hunar, Jcit, Sr. Dr सुनवाईक"तार"ख/ Date Of Hearing : 15/06/2020 घोषणाक"तार"ख/Date Of Pronouncement : 31/07/2020 आदेश / O R D E R Per Dr. A. L. Saini: The Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2014-15, Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeal)- Shillong, In Appeal No. Cit(A)/Shg/10083/2018-19 Dated 17.04.2019, Which In Turn Arises Out Of An Assessment Order Passed By The Assessing Officer U/S 143(3) / 92C(4) / 263 Of The Income Tax Act, 1961 (In Short The ‘Act’) Dated 30/11/2018. 2.When This Appeal Was Called Out For Hearing, The Ld. Counsel For The Assessee Invited Our Attention To The Order Dated 10.06.2020, Passed By The Tribunal In The Case Of M/S Raipur Steel Casting India (P) Ltd. & Srinath Ji Furnishing Pvt. Ltd. In I.T.A. No. 895& 1035/Kol/2019, For Assessment Year 2014-15.Wherein Thetribunal Held That Effect Of Omission Of Clause (I) Of Section 92Ba W.E.F 01.04.2017 Had The Effect Of It Being Omitted From Its Inception Hence, Reference

For Appellant: Shri J.P. Gupta, FCAFor Respondent: Shri T. Hunar, JCIT, Sr. DR
Section 143(3)Section 263Section 40ASection 92B

Transfer Pricing Officer by the Assessing officer after obtaining the approval of PCIT as per 92CA of the Act. In this view of the matter the benchmarking of the domestic transaction undertaken with the specified domestic parties for the purpose of determining the Arms Length Price was not done in this case. In the above conspectus, the order passed

SHREE SAI SMELTERS (I) LIMITED,BYRNIHAT vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-SHILLONG, SHILLONG

In the result, the appeal of the assessee is allowed

ITA 228/GTY/2019[2014-15]Status: DisposedITAT Guwahati31 Jul 2020AY 2014-15

Bench: Shri A. T. Varkey, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.228/Gau/2019 ("नधा"रणवष" / Assessment Year:2014-15) Shree Shai Smelters (I) Ltd. Vs. Acit, Circle-Shillong

For Appellant: Shri J.P. Gupta, FCAFor Respondent: Shri T. Hunar, JCIT, Sr. DR
Section 143(3)Section 263Section 40ASection 92B

Transfer Pricing Officer by the Assessing officer after obtaining the approval of PCIT as per 92CA of the Act. In this view of the matter the benchmarking of the domestic transaction undertaken with the specified domestic parties for the purpose of determining the Arms Length Price was not done in this case. In the above conspectus, the order passed

GREENLAM INDUSTRIES LIMITED,TINSUKIA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-TINSUKIA, TINSUKIA

In the result, appeal filed by the assessee is allowed as per the terms indicated above

ITA 402/GTY/2019[2015-16]Status: DisposedITAT Guwahati19 Dec 2022AY 2015-16

Bench: Sri Rajpal Yadav(Kz) & Dr. Manish Borad

Section 115JSection 143(2)Section 143(3)Section 244ASection 25Section 250Section 251(1)(a)Section 31(3)(a)

business or complete a project the monies must be treated as having been received for capital purposes. Page 13 of 27 I.T.A. No.: 402/Gau/2019 Assessment Year: 2015-16 Greenlam Industries Limited. 2.6.3 The Ld. Commissioner of Income Tax (Appeals), Dibrugarh, in erstwhile parent company M/s Greenply Industries Ltd.'s case for Assessment Year 2014-15, has vide order dated

D.C.I.T., CIRCLE- 1, DIBRUGARH vs. MEENAKSHI BAMALWA SONI, DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

ITA 58/GTY/2023[2012-13]Status: DisposedITAT Guwahati01 Sept 2023AY 2012-13

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

price movement in the shares of TwentyFirst Century (India) Ltd. The same was duly explained by the Assessees before the Ld. CIT(A) with the aid of analysis of price movement of other shares in the following words: “2. The A.O. had also referred to his examination of price movement in the shares of Twenty First Century (India

D.C.I.T., CIRCLE- 1, DIBRUGARH vs. BHAGWATI DEVII BAMALWA , DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

ITA 59/GTY/2023[2012-13]Status: DisposedITAT Guwahati01 Sept 2023AY 2012-13

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

price movement in the shares of TwentyFirst Century (India) Ltd. The same was duly explained by the Assessees before the Ld. CIT(A) with the aid of analysis of price movement of other shares in the following words: “2. The A.O. had also referred to his examination of price movement in the shares of Twenty First Century (India

D.C.I.T., CIRCLE- 1, DIBRUGARH vs. VISHAL BAMALWA , DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

ITA 60/GTY/2023[2012-13]Status: DisposedITAT Guwahati01 Sept 2023AY 2012-13

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

price movement in the shares of TwentyFirst Century (India) Ltd. The same was duly explained by the Assessees before the Ld. CIT(A) with the aid of analysis of price movement of other shares in the following words: “2. The A.O. had also referred to his examination of price movement in the shares of Twenty First Century (India

D.C.I.T., CIRCLE-1, DIBRUGARH vs. VINAY BAMALWA, DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

ITA 61/GTY/2023[2012-13]Status: DisposedITAT Guwahati01 Sept 2023AY 2012-13

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

price movement in the shares of TwentyFirst Century (India) Ltd. The same was duly explained by the Assessees before the Ld. CIT(A) with the aid of analysis of price movement of other shares in the following words: “2. The A.O. had also referred to his examination of price movement in the shares of Twenty First Century (India

D.C.I.T., CIRCLE-1, DIBRUGARH vs. RAVI BAMALWA, DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

ITA 62/GTY/2023[2012-13]Status: DisposedITAT Guwahati01 Sept 2023AY 2012-13

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

price movement in the shares of TwentyFirst Century (India) Ltd. The same was duly explained by the Assessees before the Ld. CIT(A) with the aid of analysis of price movement of other shares in the following words: “2. The A.O. had also referred to his examination of price movement in the shares of Twenty First Century (India