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27 results for “transfer pricing”+ Section 9(2)clear

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Key Topics

Section 143(3)12Section 92B8Section 687Addition to Income7Section 143(2)6Section 1424Section 201(1)4Transfer Pricing4Section 153(1)

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

2. The only issue raised by the assessee in the various grounds of appeal is against the order of the ld. CIT(A) in upholding the addition of Rs. 50,64,220/- as made by the AO/TPO for the specified domestic transactions entered into by the assessee. ITA No. 53 & 54/GTY/2025 Mahalaxmi Continental Ltd. Vs DCIT/ACIT 3. At the time

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 2026

Showing 1–20 of 27 · Page 1 of 2

2
Section 194C2
Exemption2
Limitation/Time-bar2
AY 2016-17

Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumar

Section 250Section 92B

2. The only issue raised by the assessee in the various grounds of appeal is against the order of the ld. CIT(A) in upholding the addition of Rs. 50,64,220/- as made by the AO/TPO for the specified domestic transactions entered into by the assessee. ITA No. 53 & 54/GTY/2025 Mahalaxmi Continental Ltd. Vs DCIT/ACIT 3. At the time

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. 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. 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. 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

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. 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. 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. 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

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

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

2. That on the facts and the circumstances of the case and in law, the Ld. CIT(A) has erred in stating that the CG fee should be benchmarked by the TPO at 0.5% without giving any scientific or logical reasoning for the same while the TPO had determined the rate based on the information available on record. 3. That