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27 results for “capital gains”+ TP Methodclear

Sorted by relevance

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Key Topics

Addition to Income17Section 143(3)9Transfer Pricing8Section 144C(13)6Section 144C6Disallowance5TP Method5Section 144C(8)3Section 1473Double Taxation/DTAA

M/S. COMPUTER SCIENCE CORPORATION INDIA PVT. LTD.,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX-CIRCLE 2(1) , INDORE

In the result, all the three appeals are partly allowed for statistical purpose and the Stay Application is also disposed of

ITA 319/IND/2018[2013-14]Status: DisposedITAT Indore10 Apr 2023AY 2013-14

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

For Appellant: Shri Vishal Kalra, AdvocateFor Respondent: Shri P.K. Mishra, CIT DR
Section 143(3)Section 144C(13)Section 144C(8)

capital adjustment as against 11.91% (which was revised to 14.85%, after depreciation adjustment) margin of the assessee. Since OP/TC margin of the assessee was greater than mean margin of the comparable companies, it was concluded that international transactions of the assessee were at arm’s length. The ITA Nos.179/Ind/2016, 292/Ind/2017, 319/Ind/2018 & SA No.46/Ind/2021 A.Ys

Showing 1–20 of 27 · Page 1 of 2

3
Limitation/Time-bar2
Condonation of Delay2

M/S. COMPUTER SCIENCE CORPORATION INDIA PVT. LTD.,CHENNAI vs. THE ACIT-CIRCLE 2(1), INDORE

In the result, all the three appeals are partly allowed for statistical purpose and the Stay Application is also disposed of

ITA 292/IND/2017[2012-13]Status: DisposedITAT Indore10 Apr 2023AY 2012-13

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

For Appellant: Shri Vishal Kalra, AdvocateFor Respondent: Shri P.K. Mishra, CIT DR
Section 143(3)Section 144C(13)Section 144C(8)

capital adjustment as against 11.91% (which was revised to 14.85%, after depreciation adjustment) margin of the assessee. Since OP/TC margin of the assessee was greater than mean margin of the comparable companies, it was concluded that international transactions of the assessee were at arm’s length. The ITA Nos.179/Ind/2016, 292/Ind/2017, 319/Ind/2018 & SA No.46/Ind/2021 A.Ys

M/S. COMPUTER SCIENCES CORPORATION INDIA PRIVATE LIMITED,INDORE vs. THE ASST. COMMISSIONER OF INCOME TAX-2(1), INDORE

In the result, all the three appeals are partly allowed for statistical purpose and the Stay Application is also disposed of

ITA 179/IND/2016[2011-12]Status: DisposedITAT Indore10 Apr 2023AY 2011-12

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

For Appellant: Shri Vishal Kalra, AdvocateFor Respondent: Shri P.K. Mishra, CIT DR
Section 143(3)Section 144C(13)Section 144C(8)

capital adjustment as against 11.91% (which was revised to 14.85%, after depreciation adjustment) margin of the assessee. Since OP/TC margin of the assessee was greater than mean margin of the comparable companies, it was concluded that international transactions of the assessee were at arm’s length. The ITA Nos.179/Ind/2016, 292/Ind/2017, 319/Ind/2018 & SA No.46/Ind/2021 A.Ys

THE ACIT, 1(1), BHOPAL vs. M/S. ANDRITZ HYDRO PVT. LTD., RAISEN

In the result, grounds taken by the assessee in all the years with respect to provision of warranty are allowed

ITA 349/IND/2016[2011-12]Status: DisposedITAT Indore28 Feb 2017AY 2011-12

Bench: Shri D.T. Garasia & Shri O.P. Meena

Section 143(3)Section 144C

TP) No. 5& 311/Ind/2011 has observed as under “8. The assessee company has debited Rs.66,90,516/- in the A.Y. 2006-07 on account of technical drawing expenses under the head “cost of raw materials and components”. The AO treated the same as expenditure in the nature of royalty within the meaning of Article 12 of DTAA with Austria

M/S. ANDRITZ HYDRO PRIVATE LIMITED (EARLIER KNOWN AS VA TECH HYDRO INDIA PRIVATE LIMITED),BHOPAL vs. THE DCIT 1(1), BHOPAL

In the result, grounds taken by the assessee in all the years with respect to provision of warranty are allowed

ITA 157/IND/2015[2010-11]Status: DisposedITAT Indore28 Feb 2017AY 2010-11

Bench: Shri D.T. Garasia & Shri O.P. Meena

Section 143(3)Section 144C

TP) No. 5& 311/Ind/2011 has observed as under “8. The assessee company has debited Rs.66,90,516/- in the A.Y. 2006-07 on account of technical drawing expenses under the head “cost of raw materials and components”. The AO treated the same as expenditure in the nature of royalty within the meaning of Article 12 of DTAA with Austria

THE DCIT, 1(1), BHOPAL vs. M/S. ANDRITZ HYDRO PVT. LTD., RAISEN

In the result, grounds taken by the assessee in all the years with respect to provision of warranty are allowed

ITA 265/IND/2015[2010-11]Status: DisposedITAT Indore28 Feb 2017AY 2010-11

Bench: Shri D.T. Garasia & Shri O.P. Meena

Section 143(3)Section 144C

TP) No. 5& 311/Ind/2011 has observed as under “8. The assessee company has debited Rs.66,90,516/- in the A.Y. 2006-07 on account of technical drawing expenses under the head “cost of raw materials and components”. The AO treated the same as expenditure in the nature of royalty within the meaning of Article 12 of DTAA with Austria

M/S ANDRITZ HYDRO PRIVATE LIMITED (EARLIER KNOWN AS V A TECH HYDRO INDAI PVT. LTD.),MANDIDEEP vs. THE ACIT 1(1), BHOPAL

In the result, grounds taken by the assessee in all the years with respect to provision of warranty are allowed

ITA 316/IND/2016[2011-12]Status: DisposedITAT Indore28 Feb 2017AY 2011-12

Bench: Shri D.T. Garasia & Shri O.P. Meena

Section 143(3)Section 144C

TP) No. 5& 311/Ind/2011 has observed as under “8. The assessee company has debited Rs.66,90,516/- in the A.Y. 2006-07 on account of technical drawing expenses under the head “cost of raw materials and components”. The AO treated the same as expenditure in the nature of royalty within the meaning of Article 12 of DTAA with Austria

THE ACIT-3(1), INDORE vs. M/S. MADHYA PRADESH AUDYOGIK KENDRA VIKAS NIGAM (I) LTD., INDORE

In the result, the appeals filed by the assessee company –

ITA 531/IND/2016[2004-05]Status: DisposedITAT Indore21 Mar 2018AY 2004-05

Bench: Shri Kul Bharat & Shri Manish Boradआ.अ.सं /.I.T.A. No. 347 To 351/Ind/2013, 760 & 761/Ind/2014 "नधा"रण वष" // A.Ys.: 2003-04, 2004-05, 2006-07 To 2008-09, 2009-10 & 2010-11 Madhya Pradesh Audyogik Vs. Assistant Commissioner Of Kendra Vikas Nigam Income-Tax, (Indore) Limited, 3(1), Indore. Indore. अपीलाथ" /Appellant ""यथ" /Respondent "था.ले.सं./Pan: Aadcm7525Q

For Respondent: Shri Manoj Munshi

capital or revenue are on behalf of the State Government and therefore the amount as received by the assessee company for and on behalf of the State Government not liable to taxed as income of the assessee but belonging to the State Government. For this preposition we rely on the following direct decisions:- 1 City and Industrial Development Appeal

THE ACIT-3(1), INDORE vs. M/S. MADHYA PRADESH AUDYOGIK KENDRA VIKAS NIGAM (I) LTD., INDORE

In the result, the appeals filed by the assessee company –

ITA 532/IND/2016[2006-07]Status: DisposedITAT Indore21 Mar 2018AY 2006-07

Bench: Shri Kul Bharat & Shri Manish Boradआ.अ.सं /.I.T.A. No. 347 To 351/Ind/2013, 760 & 761/Ind/2014 "नधा"रण वष" // A.Ys.: 2003-04, 2004-05, 2006-07 To 2008-09, 2009-10 & 2010-11 Madhya Pradesh Audyogik Vs. Assistant Commissioner Of Kendra Vikas Nigam Income-Tax, (Indore) Limited, 3(1), Indore. Indore. अपीलाथ" /Appellant ""यथ" /Respondent "था.ले.सं./Pan: Aadcm7525Q

For Respondent: Shri Manoj Munshi

capital or revenue are on behalf of the State Government and therefore the amount as received by the assessee company for and on behalf of the State Government not liable to taxed as income of the assessee but belonging to the State Government. For this preposition we rely on the following direct decisions:- 1 City and Industrial Development Appeal

M/S MADHYA PRADESH AUDYOGIK KENDRA VIKAS NIGAM (INDORE) LTD.,INDORE vs. THE ACIT3(1), INDORE

In the result, the appeals filed by the assessee company –

ITA 347/IND/2013[2003-04]Status: DisposedITAT Indore21 Mar 2018AY 2003-04

Bench: Shri Kul Bharat & Shri Manish Boradआ.अ.सं /.I.T.A. No. 347 To 351/Ind/2013, 760 & 761/Ind/2014 "नधा"रण वष" // A.Ys.: 2003-04, 2004-05, 2006-07 To 2008-09, 2009-10 & 2010-11 Madhya Pradesh Audyogik Vs. Assistant Commissioner Of Kendra Vikas Nigam Income-Tax, (Indore) Limited, 3(1), Indore. Indore. अपीलाथ" /Appellant ""यथ" /Respondent "था.ले.सं./Pan: Aadcm7525Q

For Respondent: Shri Manoj Munshi

capital or revenue are on behalf of the State Government and therefore the amount as received by the assessee company for and on behalf of the State Government not liable to taxed as income of the assessee but belonging to the State Government. For this preposition we rely on the following direct decisions:- 1 City and Industrial Development Appeal

M/S MADHYA PRADESH AUDYOGIK KENDRA VIKAS NIGAM (INDORE) LTD.,INDORE vs. THE ACIT3(1), INDORE

In the result, the appeals filed by the assessee company –

ITA 348/IND/2013[2004-05]Status: DisposedITAT Indore21 Mar 2018AY 2004-05

Bench: Shri Kul Bharat & Shri Manish Boradआ.अ.सं /.I.T.A. No. 347 To 351/Ind/2013, 760 & 761/Ind/2014 "नधा"रण वष" // A.Ys.: 2003-04, 2004-05, 2006-07 To 2008-09, 2009-10 & 2010-11 Madhya Pradesh Audyogik Vs. Assistant Commissioner Of Kendra Vikas Nigam Income-Tax, (Indore) Limited, 3(1), Indore. Indore. अपीलाथ" /Appellant ""यथ" /Respondent "था.ले.सं./Pan: Aadcm7525Q

For Respondent: Shri Manoj Munshi

capital or revenue are on behalf of the State Government and therefore the amount as received by the assessee company for and on behalf of the State Government not liable to taxed as income of the assessee but belonging to the State Government. For this preposition we rely on the following direct decisions:- 1 City and Industrial Development Appeal

M/S MADHYA PRADESH AUDYOGIK KENDRA VIKAS NIGAM (INDORE) LTD.,INDORE vs. THE ACIT3(1), INDORE

In the result, the appeals filed by the assessee company –

ITA 351/IND/2013[2008-09]Status: DisposedITAT Indore21 Mar 2018AY 2008-09

Bench: Shri Kul Bharat & Shri Manish Boradआ.अ.सं /.I.T.A. No. 347 To 351/Ind/2013, 760 & 761/Ind/2014 "नधा"रण वष" // A.Ys.: 2003-04, 2004-05, 2006-07 To 2008-09, 2009-10 & 2010-11 Madhya Pradesh Audyogik Vs. Assistant Commissioner Of Kendra Vikas Nigam Income-Tax, (Indore) Limited, 3(1), Indore. Indore. अपीलाथ" /Appellant ""यथ" /Respondent "था.ले.सं./Pan: Aadcm7525Q

For Respondent: Shri Manoj Munshi

capital or revenue are on behalf of the State Government and therefore the amount as received by the assessee company for and on behalf of the State Government not liable to taxed as income of the assessee but belonging to the State Government. For this preposition we rely on the following direct decisions:- 1 City and Industrial Development Appeal

THE ACIT-3(1), INDORE vs. M/S. MADHYA PRADESH AUDYOGIK KENDRA VIKAS NIGAM (I) LTD., INDORE

In the result, the appeals filed by the assessee company –

ITA 533/IND/2016[2007-08]Status: DisposedITAT Indore21 Mar 2018AY 2007-08

Bench: Shri Kul Bharat & Shri Manish Boradआ.अ.सं /.I.T.A. No. 347 To 351/Ind/2013, 760 & 761/Ind/2014 "नधा"रण वष" // A.Ys.: 2003-04, 2004-05, 2006-07 To 2008-09, 2009-10 & 2010-11 Madhya Pradesh Audyogik Vs. Assistant Commissioner Of Kendra Vikas Nigam Income-Tax, (Indore) Limited, 3(1), Indore. Indore. अपीलाथ" /Appellant ""यथ" /Respondent "था.ले.सं./Pan: Aadcm7525Q

For Respondent: Shri Manoj Munshi

capital or revenue are on behalf of the State Government and therefore the amount as received by the assessee company for and on behalf of the State Government not liable to taxed as income of the assessee but belonging to the State Government. For this preposition we rely on the following direct decisions:- 1 City and Industrial Development Appeal

THE ACIT-3(1), INDORE vs. M/S. MADHYA PRADESH AUDYOGIK KENDRA VIKAS NIGAM (I) LTD., INDORE

In the result, the appeals filed by the assessee company –

ITA 534/IND/2016[2008-09]Status: DisposedITAT Indore21 Mar 2018AY 2008-09

Bench: Shri Kul Bharat & Shri Manish Boradआ.अ.सं /.I.T.A. No. 347 To 351/Ind/2013, 760 & 761/Ind/2014 "नधा"रण वष" // A.Ys.: 2003-04, 2004-05, 2006-07 To 2008-09, 2009-10 & 2010-11 Madhya Pradesh Audyogik Vs. Assistant Commissioner Of Kendra Vikas Nigam Income-Tax, (Indore) Limited, 3(1), Indore. Indore. अपीलाथ" /Appellant ""यथ" /Respondent "था.ले.सं./Pan: Aadcm7525Q

For Respondent: Shri Manoj Munshi

capital or revenue are on behalf of the State Government and therefore the amount as received by the assessee company for and on behalf of the State Government not liable to taxed as income of the assessee but belonging to the State Government. For this preposition we rely on the following direct decisions:- 1 City and Industrial Development Appeal

THE ACIT-3(1), INDORE vs. M/S. MADHYA PRADESH AUDYOGIK KENDRA VIKAS NIGAM (I) LTD., INDORE

In the result, the appeals filed by the assessee company –

ITA 530/IND/2016[2003-04]Status: DisposedITAT Indore21 Mar 2018AY 2003-04

Bench: Shri Kul Bharat & Shri Manish Boradआ.अ.सं /.I.T.A. No. 347 To 351/Ind/2013, 760 & 761/Ind/2014 "नधा"रण वष" // A.Ys.: 2003-04, 2004-05, 2006-07 To 2008-09, 2009-10 & 2010-11 Madhya Pradesh Audyogik Vs. Assistant Commissioner Of Kendra Vikas Nigam Income-Tax, (Indore) Limited, 3(1), Indore. Indore. अपीलाथ" /Appellant ""यथ" /Respondent "था.ले.सं./Pan: Aadcm7525Q

For Respondent: Shri Manoj Munshi

capital or revenue are on behalf of the State Government and therefore the amount as received by the assessee company for and on behalf of the State Government not liable to taxed as income of the assessee but belonging to the State Government. For this preposition we rely on the following direct decisions:- 1 City and Industrial Development Appeal

M/S MADHYA PRADESH AUDYOGIK KENDRA VIKAS NIGAM (INDORE) LTD.,INDORE vs. THE ACIT3(1), INDORE

In the result, the appeals filed by the assessee company –

ITA 349/IND/2013[2006-07]Status: DisposedITAT Indore21 Mar 2018AY 2006-07

Bench: Shri Kul Bharat & Shri Manish Boradआ.अ.सं /.I.T.A. No. 347 To 351/Ind/2013, 760 & 761/Ind/2014 "नधा"रण वष" // A.Ys.: 2003-04, 2004-05, 2006-07 To 2008-09, 2009-10 & 2010-11 Madhya Pradesh Audyogik Vs. Assistant Commissioner Of Kendra Vikas Nigam Income-Tax, (Indore) Limited, 3(1), Indore. Indore. अपीलाथ" /Appellant ""यथ" /Respondent "था.ले.सं./Pan: Aadcm7525Q

For Respondent: Shri Manoj Munshi

capital or revenue are on behalf of the State Government and therefore the amount as received by the assessee company for and on behalf of the State Government not liable to taxed as income of the assessee but belonging to the State Government. For this preposition we rely on the following direct decisions:- 1 City and Industrial Development Appeal

M/S MADHYA PRADESH AUDYOGIK KENDRA VIKAS NIGAM (INDORE) LTD.,INDORE vs. THE ACIT3(1), INDORE

In the result, the appeals filed by the assessee company –

ITA 350/IND/2013[2007-08]Status: DisposedITAT Indore21 Mar 2018AY 2007-08

Bench: Shri Kul Bharat & Shri Manish Boradआ.अ.सं /.I.T.A. No. 347 To 351/Ind/2013, 760 & 761/Ind/2014 "नधा"रण वष" // A.Ys.: 2003-04, 2004-05, 2006-07 To 2008-09, 2009-10 & 2010-11 Madhya Pradesh Audyogik Vs. Assistant Commissioner Of Kendra Vikas Nigam Income-Tax, (Indore) Limited, 3(1), Indore. Indore. अपीलाथ" /Appellant ""यथ" /Respondent "था.ले.सं./Pan: Aadcm7525Q

For Respondent: Shri Manoj Munshi

capital or revenue are on behalf of the State Government and therefore the amount as received by the assessee company for and on behalf of the State Government not liable to taxed as income of the assessee but belonging to the State Government. For this preposition we rely on the following direct decisions:- 1 City and Industrial Development Appeal

M/S. SEZ INDORE LIMITED,INDORE vs. THE CIT-I, INDORE

In the result, the appeals filed by the assessee company –

ITA 571/IND/2014[2006-07]Status: DisposedITAT Indore21 Mar 2018AY 2006-07

Bench: Shri Kul Bharat & Shri Manish Boradआ.अ.सं /.I.T.A. No. 347 To 351/Ind/2013, 760 & 761/Ind/2014 "नधा"रण वष" // A.Ys.: 2003-04, 2004-05, 2006-07 To 2008-09, 2009-10 & 2010-11 Madhya Pradesh Audyogik Vs. Assistant Commissioner Of Kendra Vikas Nigam Income-Tax, (Indore) Limited, 3(1), Indore. Indore. अपीलाथ" /Appellant ""यथ" /Respondent "था.ले.सं./Pan: Aadcm7525Q

For Respondent: Shri Manoj Munshi

capital or revenue are on behalf of the State Government and therefore the amount as received by the assessee company for and on behalf of the State Government not liable to taxed as income of the assessee but belonging to the State Government. For this preposition we rely on the following direct decisions:- 1 City and Industrial Development Appeal

M/S. M.P. AUDHYOGIK KENDRA VIKAS NIGAM,INDORE vs. THE DCIT 3(1), INDORE

In the result, the appeals filed by the assessee company –

ITA 761/IND/2014[2010-11]Status: DisposedITAT Indore21 Mar 2018AY 2010-11

Bench: Shri Kul Bharat & Shri Manish Boradआ.अ.सं /.I.T.A. No. 347 To 351/Ind/2013, 760 & 761/Ind/2014 "नधा"रण वष" // A.Ys.: 2003-04, 2004-05, 2006-07 To 2008-09, 2009-10 & 2010-11 Madhya Pradesh Audyogik Vs. Assistant Commissioner Of Kendra Vikas Nigam Income-Tax, (Indore) Limited, 3(1), Indore. Indore. अपीलाथ" /Appellant ""यथ" /Respondent "था.ले.सं./Pan: Aadcm7525Q

For Respondent: Shri Manoj Munshi

capital or revenue are on behalf of the State Government and therefore the amount as received by the assessee company for and on behalf of the State Government not liable to taxed as income of the assessee but belonging to the State Government. For this preposition we rely on the following direct decisions:- 1 City and Industrial Development Appeal

M/S. SEZ INDORE LIMTED,INDORE vs. THE DCIT CIRCLE -3(1), INDORE

In the result, the appeals filed by the assessee company –

ITA 205/IND/2016[2009-10]Status: DisposedITAT Indore21 Mar 2018AY 2009-10

Bench: Shri Kul Bharat & Shri Manish Boradआ.अ.सं /.I.T.A. No. 347 To 351/Ind/2013, 760 & 761/Ind/2014 "नधा"रण वष" // A.Ys.: 2003-04, 2004-05, 2006-07 To 2008-09, 2009-10 & 2010-11 Madhya Pradesh Audyogik Vs. Assistant Commissioner Of Kendra Vikas Nigam Income-Tax, (Indore) Limited, 3(1), Indore. Indore. अपीलाथ" /Appellant ""यथ" /Respondent "था.ले.सं./Pan: Aadcm7525Q

For Respondent: Shri Manoj Munshi

capital or revenue are on behalf of the State Government and therefore the amount as received by the assessee company for and on behalf of the State Government not liable to taxed as income of the assessee but belonging to the State Government. For this preposition we rely on the following direct decisions:- 1 City and Industrial Development Appeal