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655 results for “transfer pricing”+ Section 2(15)clear

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Key Topics

Section 143(3)89Addition to Income75Section 6838Transfer Pricing37Section 92C34Section 153C31Section 10A27Comparables/TP27Section 144C

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-10(1), HYDERABAD vs. VERTEX PROJECTS LLP (FORMERLY M/S VERTEX PROJECTS LTD) , HYDERABAD

In the result, the appeal of Revenue is partly allowed for statistical purposes

ITA 1187/HYD/2018[2014-15]Status: DisposedITAT Hyderabad28 Apr 2023AY 2014-15

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2014-15 Acit,Circle-10(1) Vs. Vertex Projects Llp Room No.515, 5Th Floor, (Formerly M/S.Vertex A-Block, I.T.Towers, Projects Ltd.) A.C.Guards, #156-159, Paigah House Hyderabad. S.P.Road, Next To Pg College. Secunderabad-500 026. Pan : Aanfv0232C (Appellant) (Respondent) Assessee By: Shri Sriram Seshadri, Ca Revenue By: Shri Rajendra Kumar,Cit-Dr Date Of Hearing: 15.03.2023 Date Of Pronouncement: 28.04.2023 O R D E R Per Shri Laliet Kumar, J.M. This Is An Appeal Filed By The Revenue, Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-5, Dated 16.03.2018 For The Ay 2014-15, On The Following Grounds :

For Appellant: Shri Sriram Seshadri, CAFor Respondent: Shri Rajendra Kumar,CIT-DR
Section 115JSection 142(1)Section 143(2)Section 14ASection 14A(3)Section 47

Showing 1–20 of 655 · Page 1 of 33

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25
Disallowance25
Section 13224
Deduction24
Section 56
Section 56(2)(viia)
Section 56(2)(viiia)

transfer, therefore section 56(2)(viia) cannot be invoked, as this is not a case of receipt of shares in isolation but the merger of all property irrespective of shares and also 56(2)(viia) is not applicable for such amalgamation, therefore the invocation of the said section in the case of appellant is incorrect and therefore, the ground

THERMODYNE DYNAMICS PRIVATE LIMITED,HYDERABAD vs. INCOME-TAX OFFICER, WARD -17(3), HYDERABAD

ITA 500/HYD/2024[2013-2014]Status: DisposedITAT Hyderabad03 Jul 2025AY 2013-2014

Bench: Us :

For Appellant: Shri Pawan KumarFor Respondent: Shri B. Balakrishna -CIT-
Section 11USection 143(2)Section 143(3)Section 14ASection 234BSection 56

15) of section 155 shall, as far as may be, apply in relation to the stamp duty value of such property for the purpose of sub- clause (b) as they apply for valuation of capital asset under those sections : Provided further that this clause shall not apply to any sum of money or any property received-- (a) from any relative

SANGHI INDUSTRIES LIMITED,HYDERABAD vs. DCIT, CIRCLE -3 (1), HYDERABAD

In the result, the appeal of the assessee is dismissed

ITA 104/HYD/2022[2017-18]Status: DisposedITAT Hyderabad23 Jan 2025AY 2017-18

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri Vartik Choksi, ARFor Respondent: Ms. K. Haritha, CIT-DR
Section 143(3)Section 80ISection 92CSection 92E

15 years, as per section 80IA(2) of the Act. Merely because the assessee has not exercised the option will not make the eligible transaction falling either in section 80IA(8) or section 80IA(10) become ineligible. The eligible business is defined in section 80IA(4) which is not dependent upon the exercise of option by the assessee. Furthermore

ACIT., CIRCLE-5(1), HYDERABAD vs. PENNA CEMENT INDUSTRIES LIMITED, HYDERABAD

ITA 1084/HYD/2024[2018-19]Status: DisposedITAT Hyderabad21 Jan 2026AY 2018-19
For Appellant: Shri Sourabh Soparkar, Advocate Represented by Department : Dr. Narendra Kumar NFor Respondent: Dr. Narendra Kumar Naik, CIT-DR Date of Conclusion of Hearing : 11/11/2025
Section 143(3)Section 144BSection 14ASection 68Section 80Section 801ASection 80GSection 92C

Transfer Pricing Officer (TPO) in respect of specified domestic transactions reported by the assessee company. The TPO, after examining the submissions and documentation furnished by the assessee company, passed an order under section 92CA(3) of the Act, determining the arm's length price (ALP) of the specified domestic transactions and did not propose any adjustment. 4. Thereafter

SANGHI TEXTILES PRIVATE LIMITED,HYDERBAD vs. ITO., WARD-3(1), HYDERABAD

ITA 1311/HYD/2025[2014-15]Status: DisposedITAT Hyderabad07 Jan 2026AY 2014-15

Bench: Us:

Section 139(1)Section 143(2)Section 145Section 147Section 148Section 194ASection 250Section 37(1)

15 Sanghi Textiles Privarte Limited vs. ITO Commissioner of Income Tax vs. Cherian Abraham (2022) 444 ITR 420 (Karnataka). Apart from that, the Ld. AR had relied on the order of the ITAT (Special Bench), Delhi, in the case of Raj Kumar Chawla vs. ITO (2005) 1 SOT 934 (Delhi) (SB). The Ld. AR submitted that as the framing

ASST. COMMISSIONER OF INCOME TAX, (EXEMPTIONS), HYDERABAD vs. KAKATIYA URBAN DEVELOPMENT AUTHORITY , WARANGAL

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 1877/HYD/2019[2009-10]Status: DisposedITAT Hyderabad26 Dec 2022AY 2009-10

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Ms. SandhyaFor Respondent: Shri Jeevanlal Lavidiya –
Section 25l

transfer of land in relation to establishment of industrial estate or development of industrial areas and of setting up of industries cannot be said to be dealing in land or buildings for the obvious reason that the State is carrying out the objects of the Act with the Corporation as an agent in setting up industries in the State

KAKATIYA URBAN DEVELOPMENT AUTHORITY ,WARANGAL vs. ASST. COMMISSIONER OF INCOME TAX, (EXEMPTIONS), HYDERABAD

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 1722/HYD/2019[2009-10]Status: DisposedITAT Hyderabad26 Dec 2022AY 2009-10

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Ms. SandhyaFor Respondent: Shri Jeevanlal Lavidiya –
Section 25l

transfer of land in relation to establishment of industrial estate or development of industrial areas and of setting up of industries cannot be said to be dealing in land or buildings for the obvious reason that the State is carrying out the objects of the Act with the Corporation as an agent in setting up industries in the State

KAKATIYA URBAN DEVELOPMENT AUTHORITY ,WARANGAL vs. ASST. COMMISSIONER OF INCOME TAX, (EXEMPTIONS), HYDERABAD

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 1723/HYD/2019[2010-11]Status: DisposedITAT Hyderabad26 Dec 2022AY 2010-11

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Ms. SandhyaFor Respondent: Shri Jeevanlal Lavidiya –
Section 25l

transfer of land in relation to establishment of industrial estate or development of industrial areas and of setting up of industries cannot be said to be dealing in land or buildings for the obvious reason that the State is carrying out the objects of the Act with the Corporation as an agent in setting up industries in the State

ASST. COMMISSIONER OF INCOME TAX, (EXEMPTIONS), HYDERABAD vs. KAKATIYA URBAN DEVELOPMENT AUTHORITY, WARANGAL

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 1881/HYD/2019[2013-14]Status: DisposedITAT Hyderabad26 Dec 2022AY 2013-14

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Ms. SandhyaFor Respondent: Shri Jeevanlal Lavidiya –
Section 25l

transfer of land in relation to establishment of industrial estate or development of industrial areas and of setting up of industries cannot be said to be dealing in land or buildings for the obvious reason that the State is carrying out the objects of the Act with the Corporation as an agent in setting up industries in the State

KAKATIYA URBAN DEVELOPMENT AUTHORITY ,WARANGAL vs. ASST. COMMISSIONER OF INCOME TAX, (EXEMPTIONS), HYDERABAD

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 1724/HYD/2019[2011-12]Status: DisposedITAT Hyderabad26 Dec 2022AY 2011-12

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Ms. SandhyaFor Respondent: Shri Jeevanlal Lavidiya –
Section 25l

transfer of land in relation to establishment of industrial estate or development of industrial areas and of setting up of industries cannot be said to be dealing in land or buildings for the obvious reason that the State is carrying out the objects of the Act with the Corporation as an agent in setting up industries in the State

ASST. COMMISSIONER OF INCOME TAX, (EXEMPTIONS), HYDERABAD vs. KAKATIYA URBAN DEVELOPMENT AUTHORITY, WARANGAL

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 1880/HYD/2019[2012-13]Status: DisposedITAT Hyderabad26 Dec 2022AY 2012-13

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Ms. SandhyaFor Respondent: Shri Jeevanlal Lavidiya –
Section 25l

transfer of land in relation to establishment of industrial estate or development of industrial areas and of setting up of industries cannot be said to be dealing in land or buildings for the obvious reason that the State is carrying out the objects of the Act with the Corporation as an agent in setting up industries in the State

ASST. COMMISSIONER OF INCOME TAX, (EXEMPTIONS), HYDERABAD vs. KAKATIYA URBAN DEVELOPMENT AUTHORITY, HYDERABAD

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 1878/HYD/2019[2010-11]Status: DisposedITAT Hyderabad26 Dec 2022AY 2010-11

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Ms. SandhyaFor Respondent: Shri Jeevanlal Lavidiya –
Section 25l

transfer of land in relation to establishment of industrial estate or development of industrial areas and of setting up of industries cannot be said to be dealing in land or buildings for the obvious reason that the State is carrying out the objects of the Act with the Corporation as an agent in setting up industries in the State

KAKATIYA URBAN DEVELOPMENT AUTHORITY ,WARANGAL vs. ASST. COMMISSIONER OF INCOME TAX, (EXEMPTIONS), HYDERABAD

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 1726/HYD/2019[2013-14]Status: DisposedITAT Hyderabad26 Dec 2022AY 2013-14

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Ms. SandhyaFor Respondent: Shri Jeevanlal Lavidiya –
Section 25l

transfer of land in relation to establishment of industrial estate or development of industrial areas and of setting up of industries cannot be said to be dealing in land or buildings for the obvious reason that the State is carrying out the objects of the Act with the Corporation as an agent in setting up industries in the State

KAKATIYA URBAN DEVELOPMENT AUTHORITY ,WARANGAL vs. ASST. COMMISSIONER OF INCOME TAX, (EXEMPTIONS), HYDERABAD

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 1725/HYD/2019[2012-13]Status: DisposedITAT Hyderabad26 Dec 2022AY 2012-13

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Ms. SandhyaFor Respondent: Shri Jeevanlal Lavidiya –
Section 25l

transfer of land in relation to establishment of industrial estate or development of industrial areas and of setting up of industries cannot be said to be dealing in land or buildings for the obvious reason that the State is carrying out the objects of the Act with the Corporation as an agent in setting up industries in the State

ASST. COMMISSIONER OF INCOME TAX, (EXEMPTIONS), HYDERABAD vs. KAKATIYA URBAN DEVELOPMENT AUTHORITY, WARANGAL

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 1879/HYD/2019[2011-12]Status: DisposedITAT Hyderabad26 Dec 2022AY 2011-12

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Ms. SandhyaFor Respondent: Shri Jeevanlal Lavidiya –
Section 25l

transfer of land in relation to establishment of industrial estate or development of industrial areas and of setting up of industries cannot be said to be dealing in land or buildings for the obvious reason that the State is carrying out the objects of the Act with the Corporation as an agent in setting up industries in the State

DCIT, EXEMPTIONS CIRCLE, HYDERABAD vs. HYDERABAD METROPOLITAN DEVELOPMENT AUTHORITY, SECUNDERABAD

In the result, both the appeals of assessee and Revenue are allowed for statistical purposes

ITA 326/HYD/2022[2018-19]Status: DisposedITAT Hyderabad26 Dec 2022AY 2018-19

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Ms. SandhyaFor Respondent: Shri Jeevan Lal Lavidiya –
Section 11Section 139Section 139(1)

transfer of land in relation to establishment of industrial estate or development of industrial areas and of setting up of industries cannot be said to be dealing in land or buildings for the obvious reason that the State is carrying out the objects of the Act with the Corporation as an agent in setting up industries in the State

HYDERABAD METROPOLITAN DEVELOPMENT AUTHORITY,HYDERABAD vs. DCIT, EXEMPTIONS CIRCLE-1(1), HYDERABAD

In the result, both the appeals of assessee and Revenue are allowed for statistical purposes

ITA 271/HYD/2022[2018-19]Status: DisposedITAT Hyderabad26 Dec 2022AY 2018-19

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Ms. SandhyaFor Respondent: Shri Jeevan Lal Lavidiya –
Section 11Section 139Section 139(1)

transfer of land in relation to establishment of industrial estate or development of industrial areas and of setting up of industries cannot be said to be dealing in land or buildings for the obvious reason that the State is carrying out the objects of the Act with the Corporation as an agent in setting up industries in the State

ACIT., CIRCLE-5(1), HYDERABAD vs. PENNA CEMENT INDUSTRIES LIMITED, HYDERABAD

ITA 1083/HYD/2024[2017-18]Status: DisposedITAT Hyderabad21 Jan 2026AY 2017-18
Section 143(3)Section 144BSection 14ASection 68Section 80Section 801ASection 80GSection 92C

Transfer Pricing Officer\n(TPO) in respect of specified domestic transactions reported by the\nassessee company. The TPO, after examining the submissions and\ndocumentation furnished by the assessee company, passed an order\nunder section 92CA(3) of the Act, determining the arm's length price\n(ALP) of the specified domestic transactions and did not propose any\nadjustment.\n4.\nThereafter

NATEMS SOLAR POWER PRIVATE LIMITED ,HYDERABAD vs. INCOME TAX OFFICER, WARD 16(1), HYDERABAD

ITA 140/HYD/2024[2020-21]Status: DisposedITAT Hyderabad14 May 2025AY 2020-21

Bench: Us:

Section 115JSection 143(3)Section 144BSection 234Section 234A

section 92CB of the Act and Rule 10TD, providing for Safe Harbour Rules. Safe Harbour Rules provide for certain circumstances, where the transfer price declared by an eligible assessee in respect of the specified international transactions, shall be accepted to be at arm’s length by the tax authorities. The said rules recognizes above position that loans denominated in different

ABBAS ALI AKHIL,USA vs. ACIT-INT-TAX-1, HYDERABAD

In the result, the appeal of assessee in ITA No

ITA 92/HYD/2024[2016-17]Status: DisposedITAT Hyderabad29 Nov 2024AY 2016-17

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Manjunatha G. Hon’Bleआ.अपी.सं / Ita Nos.69 & 91/Hyd/2024 (निर्धारण वर्ा / Assessment Years: 2016-17 & 2018-19)

For Appellant: Shri Mohd. Afzal, AdvocateFor Respondent: Shri K. Meghnath Chowhan, CIT-DR
Section 144CSection 144C(15)Section 144C(5)Section 147Section 148Section 15Section 153(2)Section 2(14)Section 45

2) of the Act, no order of assessment or reassessment, or re-computation shall be made under Section 147, after the expiry of 12 months from the end of the financial year in which the notice under Section 148 was served. The Learned Counsel for the assessee further submitted that, if we go by the issuance of notice under Section