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141 results for “transfer pricing”+ Addition to Incomeclear

Sorted by relevance

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Key Topics

Section 143(3)149Section 8099Section 14769Section 271D67Addition to Income57Section 153A41Section 26340Section 12A37Section 6836Deduction

M/S ISOFT HEALTH MANAGEMENT (INDIA) PVT. LTD.,,CHENNAI vs. DCIT, BANGALORE

In the result, appeal of assessee is allowed

ITA 1210/BANG/2011[2007-08]Status: DisposedITAT Indore21 Aug 2023AY 2007-08

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanicomputer Sciences Dcit, Circle 11(4) Corporation India Private No. 14/3, 5Th Floor, R.P. Limited Bhawan Nrupathunga (Formerly Isoft Health Road Vs. Management (India) Pvt. Bangalore Ltd.) Unit-13, Block-2, Sdf Building Mpez Bhopal (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaaco 2465N Assessee By Shri Vishal Kalra, Ar Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 03.08.2023 Date Of Pronouncement 21.08.2023

Section 143(3)Section 144C(13)Section 144C(15)(b)Section 144C(5)Section 153(1)Section 92C

Income Tax Appellate Tribunal Rules 1963. The additional grounds of appeal are as under: “1. That on the facts and circumstances of the case and in law, the reference to the Transfer Pricing

Showing 1–20 of 141 · Page 1 of 8

...
32
Disallowance30
Exemption27

COMPUTER SCIENCES CORPORATION INDIA PRIVATE LIMITED,CHENNAI vs. ACIT, CHENNAI

ITA 1654/CHNY/2011[2007-08]Status: DisposedITAT Indore06 Oct 2023AY 2007-08

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2007-08 Computer Sciences Acit, Corporation India Private Company Circle 1(3), Limited, Chennai [Formerly Covansys (India) Private Limited], बनाम/ Unit 13, Block 2, Sdf Buildings, Vs. Madras Export Processing Zone, Tambaram, Chennai (Assessee / Appellant) (Revenue / Respondent) Pan: Aaacc1351M Assessee By Shri Neeraj Jain, Adv. Shri Abhishek Agrawal, Ca Revenue By Shri P.K. Mishra, Cit Dr Date Of Hearing 12.07.2023 Date Of Pronouncement

Section 10ASection 143(2)Section 143(3)Section 144C(5)Section 14ASection 92C

addition to the returned income on account of Transfer Pricing adjustment is only a notional income and not actual earned

M/S NIKHIL ESTATE P LTD,INDORE vs. THE ACIT CENTRAL CIRCLE (3) INDORE, INDORE

In the result, appeal of assessee is allowed

ITA 28/IND/2023[2019-20]Status: DisposedITAT Indore09 Jun 2023AY 2019-20

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S. Nikhil Estate Pvt. Ltd. Acit (Central)-3 M-102, Mezzanine, Floor, Indore Dhan Trident, P. No.B-3 Pu- Vs. 4, Sch. No.54, Vijay Nagar Square, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aabcn 8056 D Assessee By Shri S.S. Solanki, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 01.05.2023 Date Of Pronouncement 09.06.2023

Section 115BSection 133ASection 69Section 69B

price but on the basis of Delhi rates which are universally accepted on higher side. Therefore since no defects were pointed out in the books of accounts regularly maintained by the assessee and are duly audited and no incriminating material was found in the search to show that unaccounted investment in the building project has been made, addition made purely

M/S SUPREMO INDIA LTD ,INDORE vs. THE AIT CENTRAL 3, INDORE

In the result, appeal of assessee is allowed

ITA 29/IND/2023[2019-20]Status: DisposedITAT Indore07 Jun 2023AY 2019-20

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S. Supremo India Pvt. Ltd. Acit Central-3 400/2, Halka Patwari No.52 Indore Vs. Badiakeema Dudhiya, B.O. Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aafcs 9822 C Assessee By Shri S.S. Solanki, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 01.05.2023 Date Of Pronouncement 07.06.2023

Section 115BSection 131(1)Section 133ASection 69ASection 69B

additional income as business income in his return of income and paid due taxes thereon. During the course of assessment proceedings, the Assessing officer has specifically taken cognizance of these facts, as apparent on the face of the assessment order, that assessee has voluntarily surrendered Rs 1,02,00,000/- over and above the normal business income in his return

THE ACIT ,CENTRAL-1, INDORE vs. M/S PRAKASH OILS LTD., DHAR

In the result, the above captioned appeals filed by the Revenue as well as the

ITA 226/IND/2021[2012-2013]Status: DisposedITAT Indore30 Jan 2023AY 2012-2013

Bench: Shri C.M. Garg & Shri Bhagirath Mal Biyani

For Appellant: Shri Ajay Tulsian, CA &For Respondent: Shri P.K. Mishra, CIT, DR
Section 147

transfer pricing is concerned with the determination of Arm’s Length Price of the specified domestic transactions carried out by the assessee with its AE. The ld.CIT-DR drawing our attention to the order of the TPO, submitted that the ld. First appellate authority has erred in rejecting the TPO’s approach of adopting the Transactional Net Margin Method (TNMM

THE ACIT,CENTRAL-1, INDORE vs. M/S PRAKASH OILS LTD., DHAR

In the result, the above captioned appeals filed by the Revenue as well as the

ITA 235/IND/2021[2011-12]Status: DisposedITAT Indore30 Jan 2023AY 2011-12

Bench: Shri C.M. Garg & Shri Bhagirath Mal Biyani

For Appellant: Shri Ajay Tulsian, CA &For Respondent: Shri P.K. Mishra, CIT, DR
Section 147

transfer pricing is concerned with the determination of Arm’s Length Price of the specified domestic transactions carried out by the assessee with its AE. The ld.CIT-DR drawing our attention to the order of the TPO, submitted that the ld. First appellate authority has erred in rejecting the TPO’s approach of adopting the Transactional Net Margin Method (TNMM

THE ADDL. CIT RANGE -1, INDORE vs. M/S PRAKASH OILS LTD., DHAR

In the result, the above captioned appeals filed by the Revenue as well as the

ITA 227/IND/2021[2015-16]Status: DisposedITAT Indore30 Jan 2023AY 2015-16

Bench: Shri C.M. Garg & Shri Bhagirath Mal Biyani

For Appellant: Shri Ajay Tulsian, CA &For Respondent: Shri P.K. Mishra, CIT, DR
Section 147

transfer pricing is concerned with the determination of Arm’s Length Price of the specified domestic transactions carried out by the assessee with its AE. The ld.CIT-DR drawing our attention to the order of the TPO, submitted that the ld. First appellate authority has erred in rejecting the TPO’s approach of adopting the Transactional Net Margin Method (TNMM

M/S ANDRITZ HYDRO PRIVATE LIMITED,BHOPAL vs. THE DCIT CIRCLE 1(1), BHOPAL

In the result, appeal of assessee is allowed for statistical purpose

ITA 75/IND/2022[2017-18]Status: DisposedITAT Indore28 Aug 2023AY 2017-18

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S. Andritz Hydro Private Dcit Circe 1(1) Ltd. Bhopal Vs. D-17, Mpakvn Industrial Area, Mandideep Raisen (Appellant / Assessee) (Respondent/ Revenue) Pan: Aabcv 2466 R Assessee By Shri Rahul, Kaul Ar Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 13.06.2023 Date Of Pronouncement 28.08.2023

Section 143(3)Section 144C(13)Section 144C(5)Section 92C(3)

addition is proposed to the income as a result of transfer pricing review. 4.4 Ld. AR has referred to the technology

JCIT(OSD),-2(1),INDORE, INDORE vs. SHRI KESHAV KUMAR NACHANI, INDORE

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

ITA 441/IND/2018[2014-15]Status: DisposedITAT Indore25 Jan 2023AY 2014-15

Bench: Smt. Madhumita Roy & Shri Bhagirath Mal Biyani

For Appellant: Shri S. S. Deshpande, CAFor Respondent: Shri P.K. Mishra, CIT-DR
Section 132Section 132(4)Section 142(1)Section 143(2)Section 143(3)Section 153ASection 68

addition of Rs.20,27,440/-. The learned Assessing Officer has totally lost sight of the fact that the Silver Bar is of 30 Kg. Thus, the estimate has been made 30 times more on the basis of market information which is totally unrealistic, unjustified and bad in law. The appellant has sold 3972.263 Kgm of Silver Bars in different denominations

THE DCIT, 2(1), INDORE vs. SHRI KESHAV KUMAR NACHANI, INDORE

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

ITA 309/IND/2017[2013-14]Status: DisposedITAT Indore25 Jan 2023AY 2013-14

Bench: Smt. Madhumita Roy & Shri Bhagirath Mal Biyani

For Appellant: Shri S. S. Deshpande, CAFor Respondent: Shri P.K. Mishra, CIT-DR
Section 132Section 132(4)Section 142(1)Section 143(2)Section 143(3)Section 153ASection 68

addition of Rs.20,27,440/-. The learned Assessing Officer has totally lost sight of the fact that the Silver Bar is of 30 Kg. Thus, the estimate has been made 30 times more on the basis of market information which is totally unrealistic, unjustified and bad in law. The appellant has sold 3972.263 Kgm of Silver Bars in different denominations

THE DCIT, 2(1), INDORE vs. SHRI KESHAV KUMAR NACHANI, INDORE

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

ITA 244/IND/2017[2012-13]Status: DisposedITAT Indore25 Jan 2023AY 2012-13

Bench: Smt. Madhumita Roy & Shri Bhagirath Mal Biyani

For Appellant: Shri S. S. Deshpande, CAFor Respondent: Shri P.K. Mishra, CIT-DR
Section 132Section 132(4)Section 142(1)Section 143(2)Section 143(3)Section 153ASection 68

addition of Rs.20,27,440/-. The learned Assessing Officer has totally lost sight of the fact that the Silver Bar is of 30 Kg. Thus, the estimate has been made 30 times more on the basis of market information which is totally unrealistic, unjustified and bad in law. The appellant has sold 3972.263 Kgm of Silver Bars in different denominations

THE ACIT, CENTRAL-2, INDORE vs. SHRI MOHANLAL CHUGH, INDORE

In the result, the appeals of the Revenue for the A

ITA 239/IND/2017[2013-14]Status: DisposedITAT Indore23 Aug 2021AY 2013-14

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad(Virtual Hearing)

price of plots in Pulak City, Indore and made an addition of Rs.1,95,44,756/- [Rs.3,20,93,556 minus Rs.1,25,48,800] in the hands of the assessee for the A.Y. 2013-14 on account of undisclosed investment in purchase of plots in the name of assessee in Pulak City. Furthermore, an addition of Rs.1

THE ACIT, CENTRAL-2, INDORE vs. SHRI NITESH CHUGH, INDORE

In the result, the appeals of the Revenue for the A

ITA 122/IND/2017[2013-14]Status: DisposedITAT Indore23 Aug 2021AY 2013-14

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad(Virtual Hearing)

price of plots in Pulak City, Indore and made an addition of Rs.1,95,44,756/- [Rs.3,20,93,556 minus Rs.1,25,48,800] in the hands of the assessee for the A.Y. 2013-14 on account of undisclosed investment in purchase of plots in the name of assessee in Pulak City. Furthermore, an addition of Rs.1

THE ACIT, CENTRAL-2, INDORE vs. M/S. CHUGH REALTY, INDORE

In the result, the appeals of the Revenue for the A

ITA 238/IND/2017[2013-14]Status: DisposedITAT Indore23 Aug 2021AY 2013-14

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad(Virtual Hearing)

price of plots in Pulak City, Indore and made an addition of Rs.1,95,44,756/- [Rs.3,20,93,556 minus Rs.1,25,48,800] in the hands of the assessee for the A.Y. 2013-14 on account of undisclosed investment in purchase of plots in the name of assessee in Pulak City. Furthermore, an addition of Rs.1

M/S CENTURY 21 MALLS P. LTD.,INDORE vs. THE ACIT 2(1), INDORE

In the result, all appeals of the Revenue are dismissed, while all appeals of the assessee are allowed

ITA 949/IND/2016[2011-12]Status: DisposedITAT Indore23 Feb 2023AY 2011-12

Bench: Smt. Madhumita Roy & Shri Bhagirath Mal Biyani

For Appellant: Shri S. S. Deshpande, CAFor Respondent: Shri P.K. Mishra, CIT-DR
Section 132Section 143(3)Section 145(3)Section 153ASection 68

income of Rs.15 crores, which would cover the excess of credits in the ‘BM’ account, ‘21B account, and Bhopal Hoshanabad account, which the AO found to be unexplained. However, the ld.AO did not satisfy with the explanation of the assessee stating that integration of all the transactions, i.e. integration of accounts viz. (i) 21b/RSJNRS.DBF, (ii) Bhopal Hoshangabad

THE DCIT-2(1), INDORE vs. M/S. CENTURY 21 MALL (P) LTD., INDORE

In the result, all appeals of the Revenue are dismissed, while all appeals of the assessee are allowed

ITA 255/IND/2017[2012-13]Status: DisposedITAT Indore23 Feb 2023AY 2012-13

Bench: Smt. Madhumita Roy & Shri Bhagirath Mal Biyani

For Appellant: Shri S. S. Deshpande, CAFor Respondent: Shri P.K. Mishra, CIT-DR
Section 132Section 143(3)Section 145(3)Section 153ASection 68

income of Rs.15 crores, which would cover the excess of credits in the ‘BM’ account, ‘21B account, and Bhopal Hoshanabad account, which the AO found to be unexplained. However, the ld.AO did not satisfy with the explanation of the assessee stating that integration of all the transactions, i.e. integration of accounts viz. (i) 21b/RSJNRS.DBF, (ii) Bhopal Hoshangabad

THE DCIT, 2(1), INDORE vs. M/S. CENTURE 21 MALL PVT. LTD., INDORE

In the result, all appeals of the Revenue are dismissed, while all appeals of the assessee are allowed

ITA 952/IND/2016[2011-12]Status: DisposedITAT Indore23 Feb 2023AY 2011-12

Bench: Smt. Madhumita Roy & Shri Bhagirath Mal Biyani

For Appellant: Shri S. S. Deshpande, CAFor Respondent: Shri P.K. Mishra, CIT-DR
Section 132Section 143(3)Section 145(3)Section 153ASection 68

income of Rs.15 crores, which would cover the excess of credits in the ‘BM’ account, ‘21B account, and Bhopal Hoshanabad account, which the AO found to be unexplained. However, the ld.AO did not satisfy with the explanation of the assessee stating that integration of all the transactions, i.e. integration of accounts viz. (i) 21b/RSJNRS.DBF, (ii) Bhopal Hoshangabad

THE ACIT, CENTRAL-1, INDORE vs. M/S. MANISH AGRO TECH PVT. LTD., INDORE

In the result grounds of revenue for A

ITA 218/IND/2021[2012-13]Status: DisposedITAT Indore30 Jan 2023AY 2012-13

Bench: Shri Chandra Mohan Garg & Shri Bhagirath Mal Biyani

For Appellant: Shri Ruchira SinghalFor Respondent: Shri P.K Mishra, CIT (DR)

transfer pricing is concerned with the determination of Arm’s Length Price of the specified domestic transactions carried out by the assessee. The learned CIT-DR submitted that the doctrine of res judicata does not apply for the tax proceedings. Therefore the Ld. CIT(A) was not correct in deleting the impugned upward adjustment made by the TPO in respect

THE ACIT, CENTRAL-1, INDORE vs. M/S. MANISH AGRO TECH PVT. LTD., INDORE

In the result grounds of revenue for A

ITA 219/IND/2021[2015-16]Status: DisposedITAT Indore30 Jan 2023AY 2015-16

Bench: Shri Chandra Mohan Garg & Shri Bhagirath Mal Biyani

For Appellant: Shri Ruchira SinghalFor Respondent: Shri P.K Mishra, CIT (DR)

transfer pricing is concerned with the determination of Arm’s Length Price of the specified domestic transactions carried out by the assessee. The learned CIT-DR submitted that the doctrine of res judicata does not apply for the tax proceedings. Therefore the Ld. CIT(A) was not correct in deleting the impugned upward adjustment made by the TPO in respect

CUMMINS TECHNOLOGIES INDIA (P) LTD.,DEWAS vs. ACIT CIRCLE 1(1), UJJAIN

In the result, the appeal of the assesse is allowed

ITA 982/IND/2019[2015-16]Status: DisposedITAT Indore30 Nov 2023AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanicommins Technologies India Acit, Circle -1(1) Private Limited Ujjain Vs. Industrial Area No.2, A.B. Road, M.P. (Appellant / Assessee) (Revenue) Pan: Aabct2018B Assessee By Shri Ketan Ved & Pinkesh Vakharia Ars Revenue By Ms. Simran Bhullar, Cit-Dr Date Of Hearing 29.11.2023 Date Of Pronouncement 30.11.2023

Section 143(3)Section 144CSection 144C(5)

transfer pricing addition of INR 1,58,78,915/- in spite of the fact that the technical service cost was capitalized in the books (forming part of capital work-fin-progress) and no depreciation was claimed against this cost in the return of income