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153 results for “transfer pricing”+ Section 132(4)clear

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Key Topics

Section 13290Addition to Income71Search & Seizure51Section 153C45Section 153A41Section 6938Section 139(1)38Disallowance22Unexplained Investment

ACIT., CIRCLE-8(1), HYDERABAD vs. NCC HES JV, MADHAPUR

In the result, all the appeals of the Revenue are dismissed

ITA 688/HYD/2024[2018-19]Status: DisposedITAT Hyderabad11 Feb 2025AY 2018-19

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri S. Ramarao, AdvocateFor Respondent: Ms. M. Narmada, CIT-DR
Section 115JSection 142(1)Section 143(2)Section 143(3)Section 80I

pricing pressures, which is common among developers in a highly competitive sector. 16.4. We have also noted the off-balance sheet items of liabilities i.e. Contingent liabilities and observe that there's a significant increase in contingent liabilities, especially in guarantees for joint ventures and disputed tax and royalty demands, which indicate growing exposure to financial and operational risks

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Section 56(2)(x)17
Section 56(2)(vii)17
Section 5717

CELESTIAL AVENUES PVT LTD REP. BY CSK PROPERTIES PVT LTD ON MERGER-PAN-AADCC3990R,HYDERABAD. vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE -1(2), HYDERABAD.

In the result, all the appeals of the assessee are allowed

ITA 212/HYD/2024[2017-18]Status: HeardITAT Hyderabad01 Jan 2025AY 2017-18

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha G, Hon’Bleआ.अपी.सं / Ita Nos.212 To 214/Hyd/2019 (निर्धारण वर्ा / Assessment Years: 2006-07, 2007-08 & 2008-09) M/S. Sabir, Sew & The Deputy Commissioner Of Prasad, Jv, Vs. Income Tax, Hyderabad. Circle – 6(1), Hyderabad. Pan : Abcfs2425A अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent

For Appellant: Shri A. Srinivas, C.AFor Respondent: Shri Srinath Sadanala, Sr.DR
Section 132Section 143(2)Section 143(3)Section 153CSection 801ASection 801A(4)Section 80I

132 of the Act was conducted in the group cases of M/s SEW Constructions Limited and M/s. Prasad & Company (Project Works) Limited on 06.11.2007. Consequent to search action, the AO issued a notice u/s. 153C of the Act to the assessee on 17.10.2008. In response to the same, assessee filed its return of income

SABIR , SEW & PRASAD JV,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-6(1), HYDERABAD

In the result, all the appeals of the assessee are allowed

ITA 212/HYD/2019[2006-07]Status: DisposedITAT Hyderabad24 Feb 2025AY 2006-07
For Appellant: \nShri A. Srinivas, C.AFor Respondent: \nShri Srinath Sadanala, Sr.DR
Section 132Section 143(2)Section 143(3)Section 153CSection 801ASection 801A(4)Section 80I

pricing pressures,\nwhich is common among developers in a highly competitive sector.\n16. 4. We have also noted the off-balance sheet items of liabilities\ni.e. Contingent liabilities and observe that there's a significant\nincrease in contingent liabilities, especially in guarantees for joint\nventures and disputed tax and royalty demands, which indicate\ngrowing exposure to financial and operational risks

SABIR, SEW 7 PRASAD JV,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-6(1), HYDERABAD

In the result, all the appeals of the assessee are allowed

ITA 214/HYD/2019[2008-2009]Status: DisposedITAT Hyderabad24 Feb 2025AY 2008-2009
For Appellant: \nShri A. Srinivas, C.AFor Respondent: \nShri Srinath Sadanala, Sr.DR
Section 132Section 143(2)Section 143(3)Section 153CSection 80I

pricing pressures,\nwhich is common among developers in a highly competitive sector.\n\n16. 4. We have also noted the off-balance sheet items of liabilities\ni.e. Contingent liabilities and observe that there's a significant\nincrease in contingent liabilities, especially in guarantees for joint\nventures and disputed tax and royalty demands, which indicate\ngrowing exposure to financial and operational

SABIR, SEW & PRASAD JV,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-6(1), HYDERABAD

In the result, all the appeals of the assessee are allowed

ITA 213/HYD/2019[2007-08]Status: DisposedITAT Hyderabad24 Feb 2025AY 2007-08
For Appellant: \nShri A. Srinivas, C.AFor Respondent: \nShri Srinath Sadanala, Sr.DR
Section 132Section 143(2)Section 143(3)Section 153CSection 80I

pricing pressures,\nwhich is common among developers in a highly competitive sector.\n\n16. 4. We have also noted the off-balance sheet items of liabilities\ni.e. Contingent liabilities and observe that there's a significant\nincrease in contingent liabilities, especially in guarantees for joint\nventures and disputed tax and royalty demands, which indicate\ngrowing exposure to financial and operational

ACIT., CIRCLE-8(1), HYDERABAD vs. NCC HES JV, HYDERABAD

In the result, all the appeals of the Revenue are dismissed

ITA 682/HYD/2024[2017-18]Status: DisposedITAT Hyderabad11 Feb 2025AY 2017-18
For Appellant: Shri S. Ramarao, AdvocateFor Respondent: \nMs. M. Narmada, CIT-DR
Section 115JSection 142(1)Section 143(2)Section 143(3)Section 80I

price adjustment should not\nexceed 100% and the weightage for the above shall be verified\nduring each quarter and also at the final bill stage.\n- The retention money shall be retained by the officers of\nSupdt. Engineer which would be at 7.5% of the bill amount.\n- Clause 47 deals with mobilization advance is not part of the\ncontract

BHARATHI CEMENT CORPORATION PRIVATE LIMITED,,HYDERABAD vs. DCIT CIRCLE-2(1), HYDERABAD

In the result, the appeal of the assessee is allowed

ITA 159/HYD/2022[2017-18]Status: DisposedITAT Hyderabad17 Feb 2023AY 2017-18

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2017-18 Bharathi Cement Corporation Vs. Deputy Commissioner Of Private Limited, Income Tax, Hyderabad. Circle – 2(1), Hyderabad. Pan : Aadcr3079G. (Appellant) (Respondent) Assessee By: Shri S. Kalyanasundaram, Ca Revenue By: Shri Jeevan Lal Lavidiya, Cit-Dr Date Of Hearing: 14.02.2023 Date Of Pronouncement: 17.02.2023

For Appellant: Shri S. Kalyanasundaram, CAFor Respondent: Shri Jeevan Lal Lavidiya
Section 142(1)Section 143(2)Section 143(3)Section 144BSection 144CSection 144C(5)Section 80

section 80-IA of the Income Tax Act. 1961 ("Act") in respect of profits and gains made by its captive power plant. 3. For that, without prejudice to the above, the AO and the DRP have erred in law by applying a transfer price in respect of power generated by the captive power plant of the assessee to its cement

VARSHA VISWANATH PROPERTIES PRIVATE LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 1909/HYD/2018[2015-16]Status: DisposedITAT Hyderabad09 Jan 2024AY 2015-16

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

132 of the Income Tax Act, 1961 (‘the Act’) was carried out in the case of the assessee company and its group on 14/03/2016 during which certain incriminating material was found and seized. Accordingly, notice under section 153A of the Act dated 17/07/2017 was issued and served on the assessee in response to which the assessee filed the return

VARSHA VISWANATH PROPERTIES PRIVATE LIMITED ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 1906/HYD/2018[2012-13]Status: DisposedITAT Hyderabad09 Jan 2024AY 2012-13

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

132 of the Income Tax Act, 1961 (‘the Act’) was carried out in the case of the assessee company and its group on 14/03/2016 during which certain incriminating material was found and seized. Accordingly, notice under section 153A of the Act dated 17/07/2017 was issued and served on the assessee in response to which the assessee filed the return

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD vs. VARSHA VISWANATH PROPERTIES PRIVATE LIMITED , HYDERABAD

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 2046/HYD/2018[2012-13]Status: DisposedITAT Hyderabad09 Jan 2024AY 2012-13

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

132 of the Income Tax Act, 1961 (‘the Act’) was carried out in the case of the assessee company and its group on 14/03/2016 during which certain incriminating material was found and seized. Accordingly, notice under section 153A of the Act dated 17/07/2017 was issued and served on the assessee in response to which the assessee filed the return

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD vs. VARSHA VISWANATH PROPERTIES PRIVATE LIMITED, HYDERABAD

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 2049/HYD/2018[2015-16]Status: DisposedITAT Hyderabad09 Jan 2024AY 2015-16

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

132 of the Income Tax Act, 1961 (‘the Act’) was carried out in the case of the assessee company and its group on 14/03/2016 during which certain incriminating material was found and seized. Accordingly, notice under section 153A of the Act dated 17/07/2017 was issued and served on the assessee in response to which the assessee filed the return

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD vs. VARSHA VISWANATH PROPERTIES PRIVATE LIMITED, HYDERABAD

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 2050/HYD/2018[2016-17]Status: DisposedITAT Hyderabad09 Jan 2024AY 2016-17

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

132 of the Income Tax Act, 1961 (‘the Act’) was carried out in the case of the assessee company and its group on 14/03/2016 during which certain incriminating material was found and seized. Accordingly, notice under section 153A of the Act dated 17/07/2017 was issued and served on the assessee in response to which the assessee filed the return

VARSHA VISWANATH PROPERTIES PRIVATE LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 1910/HYD/2018[2016-17]Status: DisposedITAT Hyderabad09 Jan 2024AY 2016-17

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

132 of the Income Tax Act, 1961 (‘the Act’) was carried out in the case of the assessee company and its group on 14/03/2016 during which certain incriminating material was found and seized. Accordingly, notice under section 153A of the Act dated 17/07/2017 was issued and served on the assessee in response to which the assessee filed the return

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD vs. VARSHA VISWANATH PROPERTIES PRIVATE LIMITED , HYDERABAD

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 2047/HYD/2018[2013-14]Status: DisposedITAT Hyderabad09 Jan 2024AY 2013-14

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

132 of the Income Tax Act, 1961 (‘the Act’) was carried out in the case of the assessee company and its group on 14/03/2016 during which certain incriminating material was found and seized. Accordingly, notice under section 153A of the Act dated 17/07/2017 was issued and served on the assessee in response to which the assessee filed the return

VARSHA VISWANATH PROPERTIES PRIVATE LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 1907/HYD/2018[2013-14]Status: DisposedITAT Hyderabad09 Jan 2024AY 2013-14

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

132 of the Income Tax Act, 1961 (‘the Act’) was carried out in the case of the assessee company and its group on 14/03/2016 during which certain incriminating material was found and seized. Accordingly, notice under section 153A of the Act dated 17/07/2017 was issued and served on the assessee in response to which the assessee filed the return

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(3), HYDERABAD vs. VARSHA VISWANATH PROPERTIES PRIVATE LIMITED, HYDERABAD

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 2048/HYD/2018[2014-15]Status: DisposedITAT Hyderabad09 Jan 2024AY 2014-15

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

132 of the Income Tax Act, 1961 (‘the Act’) was carried out in the case of the assessee company and its group on 14/03/2016 during which certain incriminating material was found and seized. Accordingly, notice under section 153A of the Act dated 17/07/2017 was issued and served on the assessee in response to which the assessee filed the return

VARSHA VISWANATH PROPERTIES PRIVATE LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), HYDERABAD

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 1908/HYD/2018[2014-15]Status: DisposedITAT Hyderabad09 Jan 2024AY 2014-15

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

132 of the Income Tax Act, 1961 (‘the Act’) was carried out in the case of the assessee company and its group on 14/03/2016 during which certain incriminating material was found and seized. Accordingly, notice under section 153A of the Act dated 17/07/2017 was issued and served on the assessee in response to which the assessee filed the return

SUJIT AGARWAL ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2(2), HYDERABAD

In the result, the appeal of the assessee in ITA No

ITA 369/HYD/2019[2014-15]Status: DisposedITAT Hyderabad22 Nov 2023AY 2014-15

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumarassessment Year: 2014-15 Shri Sujit Agarwal Vs. Dy. C. I. T. Hyderabad Central Circle 2(2) Pan:Aclpa3197P Hyderabad (Appellant) (Respondent) Assessee By: Shri S. Rama Rao, Advocate Revenue By: Shri Ch V Gopinath, Cit(Dr) Date Of Hearing: 09/11/2023 Date Of Pronouncement: 22/11/2023 Order Per R.K. Panda, Vice-This Appeal Filed By The Assessee Is Directed Against The Order Dated 16.01.2019 Of The Learned Cit (A)-12, Hyderabad Relating To A.Y.2014-15. 2. Facts Of The Case, In Brief, Are That The Assessee Is An Individual & The Managing Director Of The Company, M/S. Sawaria Pipes Pvt Ltd. He Filed His Original Return Of Income For The Impugned A.Y On 30.12.2014 Declaring Total Income Of Rs.20,13,600/- & Agricultural Income Of Rs.70,200/-. A Search & Seizure Operation U/S 132 Of The I.T. Act Was Conducted In The Case Of The Assessee On 12.01.2016. In Response To Notice U/S 153A Of The Act Issued On 6.9.2016, The Assessee Filed His Return

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Shri CH V Gopinath, CIT(DR)
Section 10(38)Section 132Section 143(2)Section 153ASection 68

prices when the business activity of the aforesaid company was not convincing. The Assessing Officer, in the light of the above, rejected the explanation of the assessee that the share transaction in M/s. NCL Research & Financial Services Ltd were done through the broker Nirmal Bang Securities and that the payment was made through RTGS drawn on Punjab National Bank

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. HES INFRA PVT LTD., HYD, HYDERABAD

In the result, the appeal of Revenue in ITA

ITA 603/HYD/2016[2009-10]Status: DisposedITAT Hyderabad31 Jul 2023AY 2009-10

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Ms. T. Vijaya Lakshmi, CIT-DRFor Respondent: Shri A. Srinivas, C.A
Section 143(3)Section 153ASection 80I

prices of materials, cost of laborers, overhead expenses etc. Therefore the Assessee is not merely a works contractor, but was engaged in development of project as a whole, and therefore, entitled for claim of deduction under section 80IA(4) of the Act, though not being the owner of the facility. It was contended that 14 M/s. HES Infra

DCIT, CENTRAL CIRLCE-2(1), HYD, HYDERABAD vs. HES INFRA PVT LTD., HYD, HYDERABAD

In the result, the appeal of Revenue in ITA

ITA 606/HYD/2016[2012-13]Status: DisposedITAT Hyderabad31 Jul 2023AY 2012-13

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Ms. T. Vijaya Lakshmi, CIT-DRFor Respondent: Shri A. Srinivas, C.A
Section 143(3)Section 153ASection 80I

prices of materials, cost of laborers, overhead expenses etc. Therefore the Assessee is not merely a works contractor, but was engaged in development of project as a whole, and therefore, entitled for claim of deduction under section 80IA(4) of the Act, though not being the owner of the facility. It was contended that 14 M/s. HES Infra