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22 results for “transfer pricing”+ Section 2(47)clear

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Key Topics

Section 143(3)10Section 143(2)6Section 1424Section 80I4Section 92C4Transfer Pricing4Addition to Income4Section 115J3Exemption

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

47. We have heard the rival contentions, perused the relevant material available on record and carefully gone through the submissions made by the assessee before the lower authorities and before the Tribunal. Revenue is aggrieved with the finding of the ld. CIT(Appeals) deleting the arm’s length price adjustment of Rs.2,48,39,215/- made by the ld. Assessing

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

In the result, the appeal of the assessee for A

Showing 1–20 of 22 · Page 1 of 2

3
Section 153(1)2
Limitation/Time-bar2
Deduction2
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

47. We have heard the rival contentions, perused the relevant material available on record and carefully gone through the submissions made by the assessee before the lower authorities and before the Tribunal. Revenue is aggrieved with the finding of the ld. CIT(Appeals) deleting the arm’s length price adjustment of Rs.2,48,39,215/- made by the ld. Assessing

ASSAM BIO ETHANOL PRIVATE LIMITED,GUWAHATI vs. ITO W-1(1), GUWAHATI, GUWAHATI

Appeal is partly allowed

ITA 288/GTY/2024[2021-22]Status: DisposedITAT Guwahati16 Oct 2025AY 2021-22

Bench: The Drp Was That The

Section 143(3)Section 144Section 144C(3)

section 270A of the Act.” 2. Before us, right at the outset, the Ld. AR made a statement at the I.T.A. No. 288/GTY/2024 Assam Bio Ethanol Private Limited Bar that the assessee was not pressing grounds of appeal numbers, 1, 6, 7, 8 and 9. Thereafter, the Ld. AR vehemently argued that the TPO completely disregarded the transfer pricing report

D.C.I.T., CIRCLE-1, DIBRUGARH vs. BACHH RAJ 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 53/GTY/2023[2012-13]Status: DisposedITAT Guwahati01 Sept 2023AY 2012-13

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

transfer, the shares were sent to his demat a/c for credit. HDPL was amalgamated with TFCIL by order of the Hon’ble Calcutta High Court dated 23.10.2010. By virtue of the scheme of amalgamation, the Assessee was allotted on 23.12.2010, 38 shares of TFCIL against 1 share of HDPL and credited to his demat a/c. (ii) The Assessee laid special

D.C.I.T., CIRCLE-1, DIBRUGARH vs. BACHH RAJ 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 54/GTY/2023[2015-16]Status: DisposedITAT Guwahati01 Sept 2023AY 2015-16

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

transfer, the shares were sent to his demat a/c for credit. HDPL was amalgamated with TFCIL by order of the Hon’ble Calcutta High Court dated 23.10.2010. By virtue of the scheme of amalgamation, the Assessee was allotted on 23.12.2010, 38 shares of TFCIL against 1 share of HDPL and credited to his demat a/c. (ii) The Assessee laid special

D.C.I.T., CIRCLE- 1, DIBRUGARH vs. HANS RAJ 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 55/GTY/2023[2012-13]Status: DisposedITAT Guwahati01 Sept 2023AY 2012-13

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

transfer, the shares were sent to his demat a/c for credit. HDPL was amalgamated with TFCIL by order of the Hon’ble Calcutta High Court dated 23.10.2010. By virtue of the scheme of amalgamation, the Assessee was allotted on 23.12.2010, 38 shares of TFCIL against 1 share of HDPL and credited to his demat a/c. (ii) The Assessee laid special

D.C.I.T., CIRCLE- 1, DIBRUGARH vs. HANS RAJ BAMALWA (HUF), DIBRUGARH

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

ITA 56/GTY/2023[2012-13]Status: DisposedITAT Guwahati01 Sept 2023AY 2012-13

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

transfer, the shares were sent to his demat a/c for credit. HDPL was amalgamated with TFCIL by order of the Hon’ble Calcutta High Court dated 23.10.2010. By virtue of the scheme of amalgamation, the Assessee was allotted on 23.12.2010, 38 shares of TFCIL against 1 share of HDPL and credited to his demat a/c. (ii) The Assessee laid special

D.C.I.T., CIRCLE- 1, DIBRUGARH vs. USHA 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 57/GTY/2023[2012-13]Status: DisposedITAT Guwahati01 Sept 2023AY 2012-13

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

transfer, the shares were sent to his demat a/c for credit. HDPL was amalgamated with TFCIL by order of the Hon’ble Calcutta High Court dated 23.10.2010. By virtue of the scheme of amalgamation, the Assessee was allotted on 23.12.2010, 38 shares of TFCIL against 1 share of HDPL and credited to his demat a/c. (ii) The Assessee laid special

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

transfer, the shares were sent to his demat a/c for credit. HDPL was amalgamated with TFCIL by order of the Hon’ble Calcutta High Court dated 23.10.2010. By virtue of the scheme of amalgamation, the Assessee was allotted on 23.12.2010, 38 shares of TFCIL against 1 share of HDPL and credited to his demat a/c. (ii) The Assessee laid special

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

transfer, the shares were sent to his demat a/c for credit. HDPL was amalgamated with TFCIL by order of the Hon’ble Calcutta High Court dated 23.10.2010. By virtue of the scheme of amalgamation, the Assessee was allotted on 23.12.2010, 38 shares of TFCIL against 1 share of HDPL and credited to his demat a/c. (ii) The Assessee laid special

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

transfer, the shares were sent to his demat a/c for credit. HDPL was amalgamated with TFCIL by order of the Hon’ble Calcutta High Court dated 23.10.2010. By virtue of the scheme of amalgamation, the Assessee was allotted on 23.12.2010, 38 shares of TFCIL against 1 share of HDPL and credited to his demat a/c. (ii) The Assessee laid special

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

transfer, the shares were sent to his demat a/c for credit. HDPL was amalgamated with TFCIL by order of the Hon’ble Calcutta High Court dated 23.10.2010. By virtue of the scheme of amalgamation, the Assessee was allotted on 23.12.2010, 38 shares of TFCIL against 1 share of HDPL and credited to his demat a/c. (ii) The Assessee laid special

D.C.I.T., CIRCLE-1, DIBRUGARH vs. MADAN LAL 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 63/GTY/2023[2012-13]Status: DisposedITAT Guwahati01 Sept 2023AY 2012-13

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

transfer, the shares were sent to his demat a/c for credit. HDPL was amalgamated with TFCIL by order of the Hon’ble Calcutta High Court dated 23.10.2010. By virtue of the scheme of amalgamation, the Assessee was allotted on 23.12.2010, 38 shares of TFCIL against 1 share of HDPL and credited to his demat a/c. (ii) The Assessee laid special

D.C.I.T., CIRCLE-1, DIBRUGARH vs. SHEETAL 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 64/GTY/2023[2013-14]Status: DisposedITAT Guwahati01 Sept 2023AY 2013-14

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

transfer, the shares were sent to his demat a/c for credit. HDPL was amalgamated with TFCIL by order of the Hon’ble Calcutta High Court dated 23.10.2010. By virtue of the scheme of amalgamation, the Assessee was allotted on 23.12.2010, 38 shares of TFCIL against 1 share of HDPL and credited to his demat a/c. (ii) The Assessee laid special

D.C.I.T., CIRCLE-1, DIBRUGARH vs. PRAMOD KUMAR 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 65/GTY/2023[2013-14]Status: DisposedITAT Guwahati01 Sept 2023AY 2013-14

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

transfer, the shares were sent to his demat a/c for credit. HDPL was amalgamated with TFCIL by order of the Hon’ble Calcutta High Court dated 23.10.2010. By virtue of the scheme of amalgamation, the Assessee was allotted on 23.12.2010, 38 shares of TFCIL against 1 share of HDPL and credited to his demat a/c. (ii) The Assessee laid special

D.C.I.T., CIRCLE-1, DIBRUGARH vs. VINOD 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 66/GTY/2023[2013-14]Status: DisposedITAT Guwahati01 Sept 2023AY 2013-14

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

transfer, the shares were sent to his demat a/c for credit. HDPL was amalgamated with TFCIL by order of the Hon’ble Calcutta High Court dated 23.10.2010. By virtue of the scheme of amalgamation, the Assessee was allotted on 23.12.2010, 38 shares of TFCIL against 1 share of HDPL and credited to his demat a/c. (ii) The Assessee laid special

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

transfer, the shares were sent to his demat a/c for credit. HDPL was amalgamated with TFCIL by order of the Hon’ble Calcutta High Court dated 23.10.2010. By virtue of the scheme of amalgamation, the Assessee was allotted on 23.12.2010, 38 shares of TFCIL against 1 share of HDPL and credited to his demat a/c. (ii) The Assessee laid special

DCIT, CIRCLE-1, DIBRUGARH vs. BAJRANG LAL 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 51/GTY/2023[2012-13]Status: DisposedITAT Guwahati01 Sept 2023AY 2012-13

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

transfer, the shares were sent to his demat a/c for credit. HDPL was amalgamated with TFCIL by order of the Hon’ble Calcutta High Court dated 23.10.2010. By virtue of the scheme of amalgamation, the Assessee was allotted on 23.12.2010, 38 shares of TFCIL against 1 share of HDPL and credited to his demat a/c. (ii) The Assessee laid special

DCIT, CIRCLE-1, DIBRUGARH vs. BAJRANG LAL 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 52/GTY/2023[2013-14]Status: DisposedITAT Guwahati01 Sept 2023AY 2013-14

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

transfer, the shares were sent to his demat a/c for credit. HDPL was amalgamated with TFCIL by order of the Hon’ble Calcutta High Court dated 23.10.2010. By virtue of the scheme of amalgamation, the Assessee was allotted on 23.12.2010, 38 shares of TFCIL against 1 share of HDPL and credited to his demat a/c. (ii) The Assessee laid special

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