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21 results for “transfer pricing”+ Section 45(3)clear

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Key Topics

Section 92B8Section 687Addition to Income5Section 143(3)2Section 143(2)2Section 1472Section 1482Section 2502Unexplained Cash Credit

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 Guwahati13 Mar 2026AY 2016-17

Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumar

Section 250Section 92B

3. At the time of hearing, the ld. Counsel for the assessee submitted that the AO has no jurisdiction to refer the issue of determination of Arms Length Price of the specified domestic transactions of purchases with the AEs to the transfer pricing officer under clause (i) of u/s 92BA of the Act as the said section omitted with retrospective

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 Guwahati

Showing 1–20 of 21 · Page 1 of 2

2
Transfer Pricing2
Comparables/TP2
TP Method2
13 Mar 2026
AY 2015-16

Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumar

Section 250Section 92B

3. At the time of hearing, the ld. Counsel for the assessee submitted that the AO has no jurisdiction to refer the issue of determination of Arms Length Price of the specified domestic transactions of purchases with the AEs to the transfer pricing officer under clause (i) of u/s 92BA of the Act as the said section omitted with retrospective

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

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. 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

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. 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

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. 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

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. 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

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. 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. 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

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

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

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. 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

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. 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

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

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

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

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

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

MANOJ ANAND,GUWAHATI vs. ITO W-2(2) GHY, GUWAHATI

In the result, the appeal of the assessee is allowed

ITA 273/GTY/2024[2018-19]Status: DisposedITAT Guwahati02 Dec 2025AY 2018-19

Bench: Shri Rajesh Kumar, Am & Shri Manomohan Das, Jm Manoj Anand Ito W-2(2), Ghy Flat 4D, Garima Grand, Aaykar Bhawan, Christian Basti, Departmental Representative B. G.S. Road, Guwahati-781005, Vs. Baruah Road, Guwahati-781007, Assam Assam (Appellant) (Respondent) Pan No. Agbpa9883C

For Appellant: Shri Miraj D Shah, ARFor Respondent: Shri Sanjay Jha, DR
Section 144BSection 147Section 148Section 68

transferred either to Aarda Foundation or the appellant Mr. Manoj Anand on the same day. This also shows the suspicious nature of activity being carried out by M/s Urch Trading Pvt. Ltd. without any business rationale. Considering the above facts of the case and in law, I fully concur with the findings given by the AO in the assessment order

ACCRECENT WAY MARKETING (P) LTD.,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3, GUWAHATI

ITA 358/GTY/2018[2010-11]Status: DisposedITAT Guwahati09 Jun 2025AY 2010-11

Bench: Shri Manomohan Das & Shri Rakesh Mishra

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 251Section 68

45,030/- as per the details from page 39 to 42 of the paper book filed. It was also argued that the Ld. AO had not issued any notice to the assessee or 2 the investors but made the addition. The Ld. CIT(A) vide page 15 gave opportunity to the assessee but there were riots in the office which