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

Bench: Us :

6. Whether the learned Authorities below are correct in computed fair market value of each of Rs. 15.82/- under section 11UA r.w.s 56[2] [viia] of the Act, under the facts and circumstances of the case. 7. The Appellant denies the liability to pay interest under section 234B & 234C of the Act, in view of the fact that there

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

In the result, the appeal of the assessee is dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

transfer of goods or services referred to in sub-section (8) of section 80-IA; (iv) any business transacted between the assessee and other person as referred to in sub-section (10) of section 80-IA; (v) any transaction, referred to in any other section under Chapter VI- A or section 10AA, to which provisions of sub-section

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

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

Bench: Us:

Transfer Pricing Officer (TPO) were to be quashed. We further find that the Hon’ble High Court of Punjab & Haryana in the case of CIT vs. Nagendra Prasad (2013) 156 Taxmann.com 19 (Punjab & Haryana) had observed that where the notice was issued by AO under section 148 of the Act requiring the assessee to file a return within 30 days

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

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

VITP PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE8(1), HYDERABAD

2) The aggregate amount of the deductions43 under this Chapter shall not, in any\ncase, exceed the gross total income of the assessee.\n44[(3) Where, in computing the total income of an association of persons or a body\nof individuals, any deduction is admissible under section 80G or section 80GGA\n45[or section 80GGC] or section 80HH or section

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

Bench: Us:

6. Accordingly, the TPO directed the AO to enhance the total income of the assessee company by Rs.25,44,958/- u/s 92CA of the Act. 7. The AO, on receipt of the order passed by the TPO u/s 92CA(3) of the Act, dated 30.12.2022, called upon the assessee company to explain that as to why a transfer pricing adjustment

DIABETOMICS MEDICAL PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

price of\nRs.720/- per share having face value of Rs.10/- per share at\na premium of Rs.710/- per share. In support of this issue\nprice the assessee submitted the valuation report by a\nChartered Accountant under Rule-11UA(2)(b) of the I.T.\nRules, 1962 based on DCF method. During the assessment\nproceedings, the Assessing Officer did not agree with

DIABETOMICS MEDICAL PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, all the three appeals of the Assessee\nare partly allowed

price of\nRs.720/- per share having face value of Rs.10/- per share at\na premium of Rs.710/- per share. In support of this issue\nprice the assessee submitted the valuation report by a\nChartered Accountant under Rule-11UA(2)(b) of the I.T.\nRules, 1962 based on DCF method. During the assessment\nproceedings, the Assessing Officer did not agree with

DIABETOMICS MEDICAL PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

price of\nRs.720/- per share having face value of Rs.10/- per share at\na premium of Rs.710/- per share. In support of this issue\nprice the assessee submitted the valuation report by a\nChartered Accountant under Rule-11UA(2)(b) of the I.T.\nRules, 1962 based on DCF method. During the assessment\nproceedings, the Assessing Officer did not agree with

ZUARI CEMENT LIMITED,KADAPA vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1, KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

transfer pricing issues, ground no.1 is with respect to disallowance of depreciation on goodwill. This ground has already been decided in ITA 616/Hyd/2016 for A.Y. 2011-12, therefore, respectfully, following the same, we remand this ground to the file of Assessing Officer. GROUND NOS. 2 AND 3 75. Ground nos. 2 and 3 are related

ZUARI CEMENT LIMITED,KADAPA vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

transfer pricing issues, ground no.1 is with respect to disallowance of depreciation on goodwill. This ground has already been decided in ITA 616/Hyd/2016 for A.Y. 2011-12, therefore, respectfully, following the same, we remand this ground to the file of Assessing Officer. GROUND NOS. 2 AND 3 75. Ground nos. 2 and 3 are related

ZUARI CEMENT LIMITED ,KADAPA vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1, KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

transfer pricing issues, ground no.1 is with respect to disallowance of depreciation on goodwill. This ground has already been decided in ITA 616/Hyd/2016 for A.Y. 2011-12, therefore, respectfully, following the same, we remand this ground to the file of Assessing Officer. GROUND NOS. 2 AND 3 75. Ground nos. 2 and 3 are related

ZUARI CEMENT LIMITED, KADAPA,KADAPA vs. ACIT, CIRCLE-1, KADAPA, KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

transfer pricing issues, ground no.1 is with respect to disallowance of depreciation on goodwill. This ground has already been decided in ITA 616/Hyd/2016 for A.Y. 2011-12, therefore, respectfully, following the same, we remand this ground to the file of Assessing Officer. GROUND NOS. 2 AND 3 75. Ground nos. 2 and 3 are related

ZUARI CEMENT LIMITED, KADAPA,KADAPA vs. ACIT, CIRCLE-1, KADAPA, KADAPA

Accordingly, this issue is allowed for statistical purposes

Bench: Shri Laliet Kumar & Shri Laxmi Prasad Sahusl.

transfer pricing issues, ground no.1 is with respect to disallowance of depreciation on goodwill. This ground has already been decided in ITA 616/Hyd/2016 for A.Y. 2011-12, therefore, respectfully, following the same, we remand this ground to the file of Assessing Officer. GROUND NOS. 2 AND 3 75. Ground nos. 2 and 3 are related

MBS JEWELLER PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-3, HYDERABAD

In the result, both the appeals of the assessees are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2010-11 Mbs Impex Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Central Circle – 3(1), Pan – Aaccm 2968E Hyderabad. (Appellant) (Respondent) Assessment Year: 2010-11 Mbs Jeweller Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Central Circle – 3(1), Pan – Aaecm 7050M Hyderabad. (Appellant) (Respondent) Assessee By: Shri P. Murali Mohan Rao Revenue By: Shri Y.V.S.T. Sai, Cit-Dr Date Of Hearing: 13/12/2021 Date Of Pronouncement: 07/01/2022

price. Share purchase agreements with the share holder of Mis. Gold Stone Technologies Private Limited were also seized during the search. Transfer of land to assessee group is also evident from various sale deeds. :- 15 -: ITA Nos. 330 & 331/Hyd/2018 MBS Impes Pvt. Ltd. and another, Hyd. 11. It is submitted that it is evident from the statement of Shri Sukesh

MBS IMPES PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-3(1), HYDERABAD

In the result, both the appeals of the assessees are allowed in above terms

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahuassessment Year: 2010-11 Mbs Impex Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Central Circle – 3(1), Pan – Aaccm 2968E Hyderabad. (Appellant) (Respondent) Assessment Year: 2010-11 Mbs Jeweller Pvt. Ltd., Vs. Dy. Commissioner Of Hyderabad. Income-Tax, Central Circle – 3(1), Pan – Aaecm 7050M Hyderabad. (Appellant) (Respondent) Assessee By: Shri P. Murali Mohan Rao Revenue By: Shri Y.V.S.T. Sai, Cit-Dr Date Of Hearing: 13/12/2021 Date Of Pronouncement: 07/01/2022

price. Share purchase agreements with the share holder of Mis. Gold Stone Technologies Private Limited were also seized during the search. Transfer of land to assessee group is also evident from various sale deeds. :- 15 -: ITA Nos. 330 & 331/Hyd/2018 MBS Impes Pvt. Ltd. and another, Hyd. 11. It is submitted that it is evident from the statement of Shri Sukesh

VITP PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-17(2), HYDERABAD

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

6 of 10 ITA Nos. 67 & 76/Hyd/2018 1st day of June, 2010, any property, being shares of a company not being a company in which the public are substantially interested" The words "firm or a company" "any property, being shares of a company" are important here. In this regard, we may refer to the Memorandum explaining the insertion of Provisions

VITP PRIVATE LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-17(2), HYDERABAD

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

6 of 10 ITA Nos. 67 & 76/Hyd/2018 1st day of June, 2010, any property, being shares of a company not being a company in which the public are substantially interested" The words "firm or a company" "any property, being shares of a company" are important here. In this regard, we may refer to the Memorandum explaining the insertion of Provisions