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38 results for “transfer pricing”+ Section 9(1)clear

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Key Topics

Section 92B34Section 143(3)22Section 6817Addition to Income16Section 143(2)11Section 26310Section 43B8Transfer Pricing8Section 92C

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

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

Showing 1–20 of 38 · Page 1 of 2

7
Section 2506
Exemption5
Disallowance5

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

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. 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. 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

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

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 of comparables as against the Comparable Uncontrolled Price Method (CUP) followed by the assessee to benchmark the said transactions. Thus, the ld. CIT(A) justified the addition. 7. We have

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

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 of comparables as against the Comparable Uncontrolled Price Method (CUP) followed by the assessee to benchmark the said transactions. Thus, the ld. CIT(A) justified the addition. 7. We have

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