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29 results for “transfer pricing”+ Section 36(1)(iii)clear

Sorted by relevance

Delhi2,212Mumbai2,053Bangalore872Ahmedabad441Chennai429Karnataka351Kolkata310Jaipur276Hyderabad258Pune229Chandigarh206Indore167Surat146Cochin118Calcutta55SC51Visakhapatnam50Rajkot45Lucknow39Telangana38Raipur34Nagpur30Cuttack29Guwahati29Amritsar26Agra24Jodhpur19Varanasi10Dehradun9A.K. SIKRI ROHINTON FALI NARIMAN7Kerala7Rajasthan7Ranchi7Orissa6Jabalpur6Allahabad4Punjab & Haryana1Panaji1MADAN B. LOKUR S.A. BOBDE1T.S. THAKUR ROHINTON FALI NARIMAN1Andhra Pradesh1

Key Topics

Section 92B21Section 6813Section 143(3)11Section 26310Addition to Income9Section 92C7Section 143(2)5Transfer Pricing5Exemption5

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

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

Showing 1–20 of 29 · Page 1 of 2

Section 115J4
Section 201(1)4
Disallowance4

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

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. 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

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

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. 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. 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. 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

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

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

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-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