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21 results for “transfer pricing”+ Section 234clear

Sorted by relevance

Delhi407Mumbai314Karnataka290Surat132Bangalore125Ahmedabad86Jaipur67Kolkata51Chennai48Chandigarh33Pune29Hyderabad21Calcutta19Cuttack12Lucknow9Nagpur9Rajkot9Visakhapatnam8Indore8SC7Cochin7Raipur6Telangana4Varanasi4Rajasthan3A.K. SIKRI N.V. RAMANA1Andhra Pradesh1Ranchi1Allahabad1T.S. THAKUR ROHINTON FALI NARIMAN1Jodhpur1

Key Topics

Section 143(3)20Addition to Income16Section 143(2)9Section 142(1)9Section 92C9Section 1328Section 133A8Section 1278Survey u/s 133A

COMM VAULT SYSTEMS (INDIA) PVT.LTD., HYD,HYDERABAD vs. DCIT, CIRCLE-1(2), HYD, HYDERABAD

In the result, assessee’s appeal is partly allowed

ITA 343/HYD/2016[2011-12]Status: DisposedITAT Hyderabad11 Apr 2018AY 2011-12

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiahm/S. Comm Vault Systems Vs Dy. Commissioner Of Income (India) Private Limited Tax, Circle 1(2) Hyderabad Hyderabad Pan: Aaccc 3708 L (Appellant) (Respondent)

For Appellant: Shri Darpan KirpalaniFor Respondent: Shri J. Siri Kumar, DR
Section 143(3)Section 234Section 234DSection 271(1)(C)Section 92C

section 234 D of the Act on the transfer pricing adjustments. 10) Levy of penalty under section 271(1)(C), 272BA

Showing 1–20 of 21 · Page 1 of 2

8
Section 40A(3)6
Comparables/TP6
Transfer Pricing5

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

transfer pricing provisions, in our view the assessee has correctly identified the manufacturing unit as the tested party and CUP as the MAM and the purchase price of electricity in the open market from the State Electricity Board to the manufacturing units in uncontrolled conditions as the ALP. 23. Gainful reference in this regard may also be made

INFOR (INDIA) PRIVATE LIMITED ,HYDERABAD vs. DY.COMMISSIONER OF INCOME TAX, CIRLCLE-2(1), HYDERABAD

In the result, the assessee’s appeals for the A

ITA 2307/HYD/2018[2014-15]Status: DisposedITAT Hyderabad06 Aug 2019AY 2014-15

Bench: Smt. P. Madhavi Devi & Shri S.Rifaur Rahman

For Appellant: Sri Sunil Moti LalaFor Respondent: Sri Y.V.S.T. Sai, CIT-DR
Section 143(3)Section 92C

transfer pricing provisions. 5. On the facts and in the circumstances of the case and i 0 Jaw. the Ld. TPO and the Ld, AO erred in bringing notional interest to tax without considering the fact that neither the AE nor the Appellant charges any interest in case of delay in payment LEVY OF INTEREST UNDER SECTION 234

INFOR (INDIA) PRIVATE LIMITED (FORMERLY KNOWN INFOR GLOBAL SOLUTIONS (INDIA) PRIVATE LIMITED),HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(1), HYDERABAD

In the result, the assessee’s appeals for the A

ITA 161/HYD/2018[2013-14]Status: DisposedITAT Hyderabad06 Aug 2019AY 2013-14

Bench: Smt. P. Madhavi Devi & Shri S.Rifaur Rahman

For Appellant: Sri Sunil Moti LalaFor Respondent: Sri Y.V.S.T. Sai, CIT-DR
Section 143(3)Section 92C

transfer pricing provisions. 5. On the facts and in the circumstances of the case and i 0 Jaw. the Ld. TPO and the Ld, AO erred in bringing notional interest to tax without considering the fact that neither the AE nor the Appellant charges any interest in case of delay in payment LEVY OF INTEREST UNDER SECTION 234

ZUARI CEMENT LIMITED,KADAPA vs. DCIT CIRCLE -1, NELLORE

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

ITA 502/HYD/2022[2018-19]Status: DisposedITAT Hyderabad30 Dec 2024AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Deepak Chopra, Advocate and Shri Nitin Narang,C.AFor Respondent: : Shri Kumar Pranav, CIT-DR
Section 144C(5)Section 92D

Section 234C of the Act.” 3. The brief facts of the case are that, the assessee is a limited company, filed its Return of Income for A.Y. 2018-19 on 30.11.2018 declaring total income of Rs.75,31,12,150/-. The case of the assessee was selected for scrutiny under CASS. In view of the international transactions, for determination

HYDERABAD INFRATECH PRIVATE LIMITED ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-2(2), HYDERABAD

In the result, assessee’s appeal is allowed

ITA 1891/HYD/2018[2014-15]Status: DisposedITAT Hyderabad18 Oct 2019AY 2014-15

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2014-15

For Appellant: Sri K.R. VasudevanFor Respondent: Sri Y.V.S.T. Sai, CIT-DR
Section 139(1)Section 143(3)Section 234Section 92C

transfer pricing documentation maintained by the Appellant by invoking provisions of sub-section (3) of 92CA of the Act. 3. The learned AO/ learned TPO/ Hon'ble DRP erred in re- characterizing the Fully & V Compulsory Convertible Debentures ("FCCDs") issued by the Appellant to its Associated Enterprise ("AE") as a loan. 4. The learned AO/learned TPO/Hon'ble DRP erred

JASPER AUTO SERVICES PRIVATE LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1), HYDERABAD

In the result, appeal of the assessee is partly allowed for statistical purposes, in above terms

ITA 705/HYD/2020[2014-15]Status: DisposedITAT Hyderabad28 Oct 2021AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2014-15 Jasper Auto Services Pvt. Vs. Dy. Commissioner Of Ltd., Hyderabad. Income-Tax, Circle – 2(1), Hyderabad. Pan – Aaccb 0196P (Appellant) (Respondent)

For Appellant: Shri P. Murali Mohan RaoFor Respondent: Smt. N. Swapna
Section 115JSection 143(3)Section 2Section 50BSection 5O

price was fixed at Rs. 30 crores taking into account the value of various assets. These assets valued at Rs. 30 crores are sold for Rs. 92 crores. Thereafter, AOP-3, the successful bidder, deposited the amount of bid in respect of the share of nine other partners and a settlement was also prepared recording the value of the assets

ACIT, CIRCLE-17(1), HYDERABAD, HYDERABAD vs. DST WORLDWIDE SERVICES INDIA PVT. LTD., HYDERABAD, HYDERABAD

In the result, Revenue’s appeal is dismissed, while cross objections of the assessee are partly allowed

ITA 291/HYD/2015[2010-11]Status: DisposedITAT Hyderabad18 Jul 2018AY 2010-11

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiahasstt. Commissioner Of Vs M/S. Dst Worldwide Income Tax, Circle 17(1) Services India Pvt. Ltd Hyderabad Hyderabad Pan: Aaaci7097L (Appellant) (Respondent)

For Appellant: Shri Abhiroop BhagravFor Respondent: Shri J. Siri Kumar, DR
Section 10Section 10ASection 143(3)Section 92C

transfer pricing study to comparison between replicas of companies? 4. Whether on the facts and circumstances of the case, the ORP is right in law in directing the Assessing Officer to take export turnover of rupees 63,40,59,883/instead of 65,97,10,413/-taken by the Assessing Officer to calculate benefit under section 10A. 5. Whether

DY.CIT, CIR-1(2), HYDERABAD vs. M/S CUNTRY CLUB (I) LIMITED,, HYDERABAD

In the result, the grounds of the appeal of the assessee on this issue are allowed

ITA 1735/HYD/2012[2009-10]Status: DisposedITAT Hyderabad22 May 2018AY 2009-10

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2009-10 M/S Country Club Vs. Asst. Cit, Circle-1(2), Hospitality & Holidays Ltd., Hyderabad. (Formerly Known As Country Club India Ltd.,) Hyderabad.

For Appellant: Shri P. Murali Mohan RaoFor Respondent: Dr. K. Srinivas Reddy
Section 40Section 40A(3)Section 43B

234/- towards Postage & courier charges. 32. The Ld AO ought to have appreciated that the provisions of section 194C are not applicable to payments made of Rs. 4,55,600/- towards Recruitment expenses. 33. The Ld AO ought to have appreciated that the provisions of section 194C are not applicable to payments made of Rs. 53,84,615/- towards House

M/S. COUNTRY CLUB INDIA LTD.,,HYDERABAD vs. ACIT, CIRCLE-1(2), HYDERABAD

In the result, the grounds of the appeal of the assessee on this issue are allowed

ITA 1689/HYD/2012[2009-10]Status: DisposedITAT Hyderabad22 May 2018AY 2009-10

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2009-10 M/S Country Club Vs. Asst. Cit, Circle-1(2), Hospitality & Holidays Ltd., Hyderabad. (Formerly Known As Country Club India Ltd.,) Hyderabad.

For Appellant: Shri P. Murali Mohan RaoFor Respondent: Dr. K. Srinivas Reddy
Section 40Section 40A(3)Section 43B

234/- towards Postage & courier charges. 32. The Ld AO ought to have appreciated that the provisions of section 194C are not applicable to payments made of Rs. 4,55,600/- towards Recruitment expenses. 33. The Ld AO ought to have appreciated that the provisions of section 194C are not applicable to payments made of Rs. 53,84,615/- towards House

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. DSR INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

ITA 54/HYD/2024[2020-21]Status: DisposedITAT Hyderabad29 Aug 2024AY 2020-21

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

For Appellant: Shri A.V. Raghuram, Advocate for assessee at Sl.Nos.1 to 3For Respondent: Date of Hearing
Section 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)

price, receipts of amounts, etc. It is further seen from the analysis of the impounded material, the cash receipts were detected over and above the agreement value which are unaccounted. Further, as seen from the joint development agreement, M/s. DSR Infrastructure Pvt Ltd (Developer/DSR) and M/s Pioneer Builders (Land Owner/Pioneer) have an equal share in the revenues. Accordingly, the assessee

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. DSR INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

ITA 53/HYD/2024[2019-20]Status: DisposedITAT Hyderabad29 Aug 2024AY 2019-20

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

For Appellant: Shri A.V. Raghuram, Advocate for assessee at Sl.Nos.1 to 3For Respondent: Date of Hearing
Section 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)

price, receipts of amounts, etc. It is further seen from the analysis of the impounded material, the cash receipts were detected over and above the agreement value which are unaccounted. Further, as seen from the joint development agreement, M/s. DSR Infrastructure Pvt Ltd (Developer/DSR) and M/s Pioneer Builders (Land Owner/Pioneer) have an equal share in the revenues. Accordingly, the assessee

D S R INFRASTRUCTUREPRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE- 1(4), HYDERABAD

In the result, the appeals of Revenue in ITA Nos

ITA 49/HYD/2024[2019-20]Status: DisposedITAT Hyderabad29 Aug 2024AY 2019-20

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

For Appellant: Shri A.V. Raghuram, Advocate for assessee at Sl.Nos.1 to 3For Respondent: Date of Hearing
Section 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)

price, receipts of amounts, etc. It is further seen from the analysis of the impounded material, the cash receipts were detected over and above the agreement value which are unaccounted. Further, as seen from the joint development agreement, M/s. DSR Infrastructure Pvt Ltd (Developer/DSR) and M/s Pioneer Builders (Land Owner/Pioneer) have an equal share in the revenues. Accordingly, the assessee

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. PIONEER BUILDERS, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

ITA 56/HYD/2024[2019-20]Status: DisposedITAT Hyderabad29 Aug 2024AY 2019-20

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

For Appellant: Shri A.V. Raghuram, Advocate for assessee at Sl.Nos.1 to 3For Respondent: Date of Hearing
Section 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)

price, receipts of amounts, etc. It is further seen from the analysis of the impounded material, the cash receipts were detected over and above the agreement value which are unaccounted. Further, as seen from the joint development agreement, M/s. DSR Infrastructure Pvt Ltd (Developer/DSR) and M/s Pioneer Builders (Land Owner/Pioneer) have an equal share in the revenues. Accordingly, the assessee

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. PIONEER BUILDERS, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

ITA 57/HYD/2024[2020-21]Status: DisposedITAT Hyderabad29 Aug 2024AY 2020-21

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

For Appellant: Shri A.V. Raghuram, Advocate for assessee at Sl.Nos.1 to 3For Respondent: Date of Hearing
Section 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)

price, receipts of amounts, etc. It is further seen from the analysis of the impounded material, the cash receipts were detected over and above the agreement value which are unaccounted. Further, as seen from the joint development agreement, M/s. DSR Infrastructure Pvt Ltd (Developer/DSR) and M/s Pioneer Builders (Land Owner/Pioneer) have an equal share in the revenues. Accordingly, the assessee

D S R INFRASTRUCTURE PRIVATE LIMITED ,HYDERABAD vs. DCIT., CENTRAL CIRCLE-1(4), HYDERABAD

In the result, the appeals of Revenue in ITA Nos

ITA 51/HYD/2024[2020-21]Status: DisposedITAT Hyderabad29 Aug 2024AY 2020-21

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

For Appellant: Shri A.V. Raghuram, Advocate for assessee at Sl.Nos.1 to 3For Respondent: Date of Hearing
Section 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)

price, receipts of amounts, etc. It is further seen from the analysis of the impounded material, the cash receipts were detected over and above the agreement value which are unaccounted. Further, as seen from the joint development agreement, M/s. DSR Infrastructure Pvt Ltd (Developer/DSR) and M/s Pioneer Builders (Land Owner/Pioneer) have an equal share in the revenues. Accordingly, the assessee

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), HYDERABAD vs. PIONEER BUILDERS, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

ITA 64/HYD/2024[2019-20]Status: DisposedITAT Hyderabad29 Aug 2024AY 2019-20

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

For Appellant: Shri A.V. Raghuram, Advocate for assessee at Sl.Nos.1 to 3For Respondent: Date of Hearing
Section 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)

price, receipts of amounts, etc. It is further seen from the analysis of the impounded material, the cash receipts were detected over and above the agreement value which are unaccounted. Further, as seen from the joint development agreement, M/s. DSR Infrastructure Pvt Ltd (Developer/DSR) and M/s Pioneer Builders (Land Owner/Pioneer) have an equal share in the revenues. Accordingly, the assessee

DCIT., CENTRAL CIRCLE-1(4), HYDERABAD vs. DSR INFRASTRUCTURE PRIVATE LIMITED, HYDERABAD

In the result, the appeals of Revenue in ITA Nos

ITA 50/HYD/2024[2019-20]Status: DisposedITAT Hyderabad29 Aug 2024AY 2019-20

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

For Appellant: Shri A.V. Raghuram, Advocate for assessee at Sl.Nos.1 to 3For Respondent: Date of Hearing
Section 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)

price, receipts of amounts, etc. It is further seen from the analysis of the impounded material, the cash receipts were detected over and above the agreement value which are unaccounted. Further, as seen from the joint development agreement, M/s. DSR Infrastructure Pvt Ltd (Developer/DSR) and M/s Pioneer Builders (Land Owner/Pioneer) have an equal share in the revenues. Accordingly, the assessee

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. HSBC ELECTRONIC DATA PROCESSING INDIA PRIVATE LIMITED, , HYDERABAD

In the result, the appeal filed by the Revenue is dismissed

ITA 1632/HYD/2017[2010-11]Status: DisposedITAT Hyderabad05 Aug 2024AY 2010-11

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri Rajan Vora, C.AFor Respondent: : Shri Kumar Pranav, CIT-DR
Section 10ASection 115Section 115JSection 251(1)(a)Section 37(1)Section 41(1)

transferred to unclaimed liabilities account. The assessee, during the appellate proceedings furnished the details of these unclaimed liabilities as additional evidence and the same was sent to Assessing officer for factual report. However, till date no report is received. 7.1 On perusal of the details furnished it is seen that in case of many entries there is not even

GOLDGREEN LAND HOLDINGS LLP( FORMERLY GOLD GREEN HOLDINGS PRIVATE LIMITED),SHANKARPALLY MANDAL, MIRZAGUDA vs. INCOME TAX OFFICER - WARD 2(1), HYDERABAD

In the result, appeal of the assessee is treated as allowed for statistical purposes

ITA 473/HYD/2023[2017-2018]Status: DisposedITAT Hyderabad22 Mar 2024AY 2017-2018

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Charyआ.अपी.सं / Ita No. 473/Hyd/2023 (धििाारण वर्ा / Assessment Year: 2017-18) Goldgreen Land Holdings Llp Vs. Income Tax Officer, (Formerly Gold Green Holdings Ward-2(1), Private Limited), Hyderabad Shankarpally Mandal, Mirzaguda [Pan No. Aadcg2864N] अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent धििााररती द्वारा / Assessee By: Shri Kumar Pal Tated, Ar राजस्‍व द्वारा / Revenue By: Shri Shakeer Ahamed, Dr सुिवाई की तारीख/Date Of Hearing: 06/03/2024 घोर्णा की तारीख/Pronouncement On: 22/03/2024 आदेश / Order Per K. Narasimha Chary, J.M: Aggrieved By The Order Dated 07/08/2023 Passed By The Learned Commissioner Of Income Tax (Appeals)- National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”), In The Case Of Goldgreen Land Holdings Private Limited (“The Assessee”) For The Assessment Year 2017-18, Assessee Preferred This Appeal.

For Appellant: Shri Kumar Pal Tated, ARFor Respondent: Shri Shakeer Ahamed, DR
Section 143(3)Section 2(14)Section 48Section 50C

234/-. During the course of assessment proceedings the learned Assessing Officer proposed to tax on the gain of Rs. 5,35,52,434/- arised on sale of agriculture land Situated at Vattinagulapally and Janwada Villages, by enclosing screen shot maps showing the distance of the property from the limits of Municipality as less than the prescribed limit. 3. Assessee submitted