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172 results for “transfer pricing”+ Deductionclear

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Key Topics

Section 143(3)129Section 8080Addition to Income65Section 14757Section 26348Section 12A39Section 153A36Section 80I34Disallowance33

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

transfer pricing documentation requirements. 12. The ld. AO and Hon'ble DRP have erred, in law and in facts, by applying the turnover ≤ Rs. 1 crore as a comparability criterion. 13. The ld. AO and Hon'ble DRP have erred, in law and in facts, by rejecting certain comparable companies identified by the assessee as having economic performance contrary

Showing 1–20 of 172 · Page 1 of 9

...
Deduction33
Section 10(38)28
Exemption21

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

deducted at source of INR 26,920. The above grounds are independent and without prejudice, to each other unless mentioned specifically. T.P.A. No. 316/Ind/2016:A.Y. 2011-12 Transfer Pricing

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

deducted at source of INR 26,920. The above grounds are independent and without prejudice, to each other unless mentioned specifically. T.P.A. No. 316/Ind/2016:A.Y. 2011-12 Transfer Pricing

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

deducted at source of INR 26,920. The above grounds are independent and without prejudice, to each other unless mentioned specifically. T.P.A. No. 316/Ind/2016:A.Y. 2011-12 Transfer Pricing

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

deducted at source of INR 26,920. The above grounds are independent and without prejudice, to each other unless mentioned specifically. T.P.A. No. 316/Ind/2016:A.Y. 2011-12 Transfer Pricing

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 regulations w.e.f. 01.04.2017. After omission of Section 92BA(i), such CO Nos.2 to 4/Ind/2022 transactions will not fall under the definition of Specified Domestic Transaction and therefore, the provisions of transfer pricing will not be applicable on such transactions. 5.3. It is submitted that clause (i) of section 92BA was omitted from the statute by the Finance

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 regulations w.e.f. 01.04.2017. After omission of Section 92BA(i), such CO Nos.2 to 4/Ind/2022 transactions will not fall under the definition of Specified Domestic Transaction and therefore, the provisions of transfer pricing will not be applicable on such transactions. 5.3. It is submitted that clause (i) of section 92BA was omitted from the statute by the Finance

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 regulations w.e.f. 01.04.2017. After omission of Section 92BA(i), such CO Nos.2 to 4/Ind/2022 transactions will not fall under the definition of Specified Domestic Transaction and therefore, the provisions of transfer pricing will not be applicable on such transactions. 5.3. It is submitted that clause (i) of section 92BA was omitted from the statute by the Finance

THE ACIT, - 4(1), INDORE vs. M/S. YASH TECHNOLOGIES PVT. LTD., INDORE

In the result appeal of the revenue is dismissed

ITA 616/IND/2018[2014-15]Status: DisposedITAT Indore31 Oct 2019AY 2014-15

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Boradassessment Year 2014-15 Pan : Aaacy1868M

Section 10ASection 115JSection 143(3)Section 28Section 40

transfer pricing. In support of its 11 Yash Technologies Pvt. Ltd contention CBDT instruction No. 3 of 2016 was referred which speaks of determination of ALP in specified domestic transaction. 7.2 The appellant further stated that even otherwise the AO was factually incorrect that the salaries of eight employees mentioned by him are debited in non SEZ. The fact

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 filed by the Assessee for the year under consideration. 5.4 On the facts and in circumstances

INDORE DEVELOPMENT AUTHORITY ,INDORE vs. DCIT (EXEMPTION CIRCLE), BHOPAL

Appeals are allowed and revenue’s appeals

ITA 143/IND/2024[2018-19]Status: DisposedITAT Indore01 Jan 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 11Section 12ASection 143(3)Section 2(15)

deduction under the heading “IMC Transfer Expenses”. The AO disallowed such expenses but in first-appeal, the CIT(A) reversed AO’s action and deleted disallowance. For this issue, we straightaway refer the order passed by Ld. CIT(A) which vehemently narrates the premise on which the AO made Page 17 of 29 Indore Development Authority ITA Nos. 8/Ind/2024

INDORE DEVELOPMENT AUTHORITY ,INDORE vs. DCIT ( EXEMPTION CIRCLE) , BHOPAL

Appeals are allowed and revenue’s appeals

ITA 144/IND/2024[2021-22]Status: DisposedITAT Indore01 Jan 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 11Section 12ASection 143(3)Section 2(15)

deduction under the heading “IMC Transfer Expenses”. The AO disallowed such expenses but in first-appeal, the CIT(A) reversed AO’s action and deleted disallowance. For this issue, we straightaway refer the order passed by Ld. CIT(A) which vehemently narrates the premise on which the AO made Page 17 of 29 Indore Development Authority ITA Nos. 8/Ind/2024

INDORE DEVELOPMENT AUTHORITY,INDORE vs. DCIT (EXEMPTION CIRCLE), BHOPAL

Appeals are allowed and revenue’s appeals

ITA 141/IND/2024[2015-16]Status: DisposedITAT Indore01 Jan 2025AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 11Section 12ASection 143(3)Section 2(15)

deduction under the heading “IMC Transfer Expenses”. The AO disallowed such expenses but in first-appeal, the CIT(A) reversed AO’s action and deleted disallowance. For this issue, we straightaway refer the order passed by Ld. CIT(A) which vehemently narrates the premise on which the AO made Page 17 of 29 Indore Development Authority ITA Nos. 8/Ind/2024

DEPUTY COMMISSIONER OF INCOME TAX(EXEMPTION), BHOPAL, BHOPAL vs. INDORE DEVELOPMENT AUTHORITY, INDORE

Appeals are allowed and revenue’s appeals

ITA 137/IND/2024[2015-16]Status: DisposedITAT Indore01 Jan 2025AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 11Section 12ASection 143(3)Section 2(15)

deduction under the heading “IMC Transfer Expenses”. The AO disallowed such expenses but in first-appeal, the CIT(A) reversed AO’s action and deleted disallowance. For this issue, we straightaway refer the order passed by Ld. CIT(A) which vehemently narrates the premise on which the AO made Page 17 of 29 Indore Development Authority ITA Nos. 8/Ind/2024

DEPUTY COMMISSIONER OF INCOME TAX(EXEMPTION), BHOPAL, BHOPAL, MADHYA PRADESH vs. INDORE DEVELOPMENT AUTHORITY, INDORE

Appeals are allowed and revenue’s appeals

ITA 113/IND/2024[2014-15]Status: DisposedITAT Indore01 Jan 2025AY 2014-15

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 11Section 12ASection 143(3)Section 2(15)

deduction under the heading “IMC Transfer Expenses”. The AO disallowed such expenses but in first-appeal, the CIT(A) reversed AO’s action and deleted disallowance. For this issue, we straightaway refer the order passed by Ld. CIT(A) which vehemently narrates the premise on which the AO made Page 17 of 29 Indore Development Authority ITA Nos. 8/Ind/2024

DEPUTY COMMISSIONER OF INCOME TAX(EXEMPTION), BHOPAL, BHOPAL vs. INDORE DEVELOPMENT AUTHORITY, INDORE

Appeals are allowed and revenue’s appeals

ITA 138/IND/2024[2016-17]Status: DisposedITAT Indore01 Jan 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 11Section 12ASection 143(3)Section 2(15)

deduction under the heading “IMC Transfer Expenses”. The AO disallowed such expenses but in first-appeal, the CIT(A) reversed AO’s action and deleted disallowance. For this issue, we straightaway refer the order passed by Ld. CIT(A) which vehemently narrates the premise on which the AO made Page 17 of 29 Indore Development Authority ITA Nos. 8/Ind/2024

DEPUTY COMMISSIONER OF INCOME TAX, EXEMPTION, BHOPAL, BHOPAL vs. INDORE DEVELOPMENT AUTHORITY, INDORE, INDORE

Appeals are allowed and revenue’s appeals

ITA 136/IND/2024[2021-22]Status: DisposedITAT Indore01 Jan 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 11Section 12ASection 143(3)Section 2(15)

deduction under the heading “IMC Transfer Expenses”. The AO disallowed such expenses but in first-appeal, the CIT(A) reversed AO’s action and deleted disallowance. For this issue, we straightaway refer the order passed by Ld. CIT(A) which vehemently narrates the premise on which the AO made Page 17 of 29 Indore Development Authority ITA Nos. 8/Ind/2024

DEPUTY COMMISSIONER OF INCOME TAX(EXEMPTION), BHOPAL, BHOPAL vs. INDORE DEVELOPMENT AUTHORITY, INDORE

Appeals are allowed and revenue’s appeals

ITA 139/IND/2024[2018-19]Status: DisposedITAT Indore01 Jan 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 11Section 12ASection 143(3)Section 2(15)

deduction under the heading “IMC Transfer Expenses”. The AO disallowed such expenses but in first-appeal, the CIT(A) reversed AO’s action and deleted disallowance. For this issue, we straightaway refer the order passed by Ld. CIT(A) which vehemently narrates the premise on which the AO made Page 17 of 29 Indore Development Authority ITA Nos. 8/Ind/2024