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223 results for “transfer pricing”+ Section 143clear

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Key Topics

Section 143(3)144Addition to Income57Section 8055Section 12A44Section 10(38)40Section 153A38Section 14737Section 26333Exemption31

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

Section 143(3) r.w.s. 1440 of the Income Tax Act, 1961 ("the Act") for Page 1 of 15 Computer Sciences Corporation India Pvt. Ltd. Page 2 of 15 assessment year 2007-08 passed by the Deputy Commissioner of Income Tax, Bangalore (hereinafter referred to as ("Ld. AO"), 1. That on facts and circumstances of the case

Showing 1–20 of 223 · Page 1 of 12

...
Section 6830
Disallowance22
Deduction21

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

section 145(3) of the Act. He accordingly reversed the action of the AO in rejecting the books of accounts of the assessee by holding that the AO was not correct in rejecting the books of accounts. Thereafter, the ld.CIT(A) deleted additions made on account of estimation of gross profit in the transactions of sale of gold and silver

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

section 145(3) of the Act. He accordingly reversed the action of the AO in rejecting the books of accounts of the assessee by holding that the AO was not correct in rejecting the books of accounts. Thereafter, the ld.CIT(A) deleted additions made on account of estimation of gross profit in the transactions of sale of gold and silver

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

section 145(3) of the Act. He accordingly reversed the action of the AO in rejecting the books of accounts of the assessee by holding that the AO was not correct in rejecting the books of accounts. Thereafter, the ld.CIT(A) deleted additions made on account of estimation of gross profit in the transactions of sale of gold and silver

MAHENDRA SINGH CHAWLA,INDORE vs. DCIT CIRCLE-1(1), INDORE

In the result, the appeal of the assessee is dismissed

ITA 245/IND/2024[2017-18]Status: HeardITAT Indore04 Sept 2024AY 2017-18

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanimahendra Singh Chawla Dcit Circle -1(1) 4/35 Gram Pigdamber A.B. Indore Road Near Rao Vs. Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aazpc0120C Assessee By None Shri Ashish Porwal, Sr. Dr Revenue By Date Of Hearing 02.09.2024 Date Of Pronouncement 04 .09.2024

Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 54

143(2) dated 10.08.2018 by ACIT-4(1) Indore. Thereafter no Page 3 of 21 ITANo.245/Ind/2024 Mahendra Singh Chawla proceedings were carried out by the Department for a period of more than one year. Later, the case was transferred to the office of DCIT-1(1) on 20.08.2019, who by issuing Notice u/s 142(1) dated 08.11.2019 has recommenced

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

section 92CA(3) & 144C(5) of the Income-tax Act, 1961 for Assessment-Year [“AY”] 2007-08, the assessee has filed this appeal. Page 1 of 47 Computer Sciences Corporation India Private Limited, Chennai Assessment year 2007-08 2. This appeal was originally filed at Chennai Bench of ITAT on 10.10.2011 and registered as ITA No. 1654/CHNY/2011. The ITAT, Chennai

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 figure is Rs.3,46,13,572/- which is less than 5 Crores hence the provisions of Specified Domestic Transaction as per Section 92BA does not apply. (b )(i) That even otherwise the AO was factually incorrect in mentioning that 8 employees mentioned are in Non SEZ whereas out of 8 employees, 5 employees' salary is debited

MS MAPAEX REMEDIES PVT LTD,BHOPAL vs. ACIT 2 (1) BHOPAL, BHOPAL MADHYA PRADESH

Appeals are dismissed

ITA 489/IND/2024[2017-18]Status: DisposedITAT Indore10 Sept 2024AY 2017-18

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

Section 143(2)Section 143(3)Section 147Section 148Section 80

143(3) r.w.s. 147 of the Act dated 30.12.2019 and circumvented the intention of legislature towards deduction u/s 80-IC of the Act, by misinterpreting the plane and lucid meaning of section 80-IC of the Act and allowing deduction u/s 80-IC to a service provider, however, the same is available only for taxpayers involving in manufacturing activities

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 5 1, BHOPAL , BHOPAL MADHYA PRADESH vs. MAPAEX REMEDIES PVT LTD, BHOPAL MADHYA PRADESH

Appeals are dismissed

ITA 510/IND/2024[2017-18]Status: DisposedITAT Indore10 Sept 2024AY 2017-18

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

Section 143(2)Section 143(3)Section 147Section 148Section 80

143(3) r.w.s. 147 of the Act dated 30.12.2019 and circumvented the intention of legislature towards deduction u/s 80-IC of the Act, by misinterpreting the plane and lucid meaning of section 80-IC of the Act and allowing deduction u/s 80-IC to a service provider, however, the same is available only for taxpayers involving in manufacturing activities

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE - 5(1), BHOPAL , BHOPAL MADHYA PRADESH vs. MAPAEX REMEDIES PVT LTD, BHOPAL MADHYA PRADESH

Appeals are dismissed

ITA 509/IND/2024[2016-17]Status: DisposedITAT Indore10 Sept 2024AY 2016-17

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

Section 143(2)Section 143(3)Section 147Section 148Section 80

143(3) r.w.s. 147 of the Act dated 30.12.2019 and circumvented the intention of legislature towards deduction u/s 80-IC of the Act, by misinterpreting the plane and lucid meaning of section 80-IC of the Act and allowing deduction u/s 80-IC to a service provider, however, the same is available only for taxpayers involving in manufacturing activities

MS MAPAEX REMEDIES PVT LTD,BHOPAL vs. ACIT 2 (1) BHOPAL, BHOPAL

Appeals are dismissed

ITA 486/IND/2024[2012-13 ]Status: DisposedITAT Indore10 Sept 2024

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

Section 143(2)Section 143(3)Section 147Section 148Section 80

143(3) r.w.s. 147 of the Act dated 30.12.2019 and circumvented the intention of legislature towards deduction u/s 80-IC of the Act, by misinterpreting the plane and lucid meaning of section 80-IC of the Act and allowing deduction u/s 80-IC to a service provider, however, the same is available only for taxpayers involving in manufacturing activities

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -5(1), BHOPAL , BHOPAL, MADHYA PRADESH vs. MAPAEX REMEDIES PVT. LTD., BHOPAL MADHYA PRADESH

Appeals are dismissed

ITA 508/IND/2024[2012-13]Status: DisposedITAT Indore10 Sept 2024AY 2012-13

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

Section 143(2)Section 143(3)Section 147Section 148Section 80

143(3) r.w.s. 147 of the Act dated 30.12.2019 and circumvented the intention of legislature towards deduction u/s 80-IC of the Act, by misinterpreting the plane and lucid meaning of section 80-IC of the Act and allowing deduction u/s 80-IC to a service provider, however, the same is available only for taxpayers involving in manufacturing activities

MAPAEX REMEDIES PVT LTD ,BHOPAL vs. THE DCIT -2- (1), BHOPAL , BHOPAL

Appeals are dismissed

ITA 444/IND/2024[2016-17]Status: DisposedITAT Indore10 Sept 2024AY 2016-17

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

Section 143(2)Section 143(3)Section 147Section 148Section 80

143(3) r.w.s. 147 of the Act dated 30.12.2019 and circumvented the intention of legislature towards deduction u/s 80-IC of the Act, by misinterpreting the plane and lucid meaning of section 80-IC of the Act and allowing deduction u/s 80-IC to a service provider, however, the same is available only for taxpayers involving in manufacturing activities

THE ACIT, CENTRAL-1, INDORE vs. M/S SURYA INFRA VENTURE PVT. LTD., INDORE

ITA 232/IND/2021[2012-13]Status: DisposedITAT Indore24 Nov 2022AY 2012-13

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

Section 143(3)Section 37Section 40A(3)Section 40a

transfer to appellants bank account. Further, copy of ledger account of the appellant in the books of the investor company and copy of confirmation has also been filed. The appellant had duly issued shares against funds received from the investor company. The appellant company has received total sum sum of Rs. 1,35,00,000/- against which

THE AIT,ENTRAL-1, INDORE vs. SURYA INFRAVENTURE P LTD, INDORE

ITA 217/IND/2021[201-13]Status: DisposedITAT Indore24 Nov 2022

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

Section 143(3)Section 37Section 40A(3)Section 40a

transfer to appellants bank account. Further, copy of ledger account of the appellant in the books of the investor company and copy of confirmation has also been filed. The appellant had duly issued shares against funds received from the investor company. The appellant company has received total sum sum of Rs. 1,35,00,000/- against which

THE ACIT, CIRCLE 2(1), INDORE vs. M/S SURYA INFRA VENTURE PVT. LTD., INDORE

ITA 216/IND/2021[2010-11]Status: DisposedITAT Indore24 Nov 2022AY 2010-11

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

Section 143(3)Section 37Section 40A(3)Section 40a

transfer to appellants bank account. Further, copy of ledger account of the appellant in the books of the investor company and copy of confirmation has also been filed. The appellant had duly issued shares against funds received from the investor company. The appellant company has received total sum sum of Rs. 1,35,00,000/- against which

THE DCIT-3(1), INDORE vs. KUMARI SHEETAL GARG, INDORE

In the result Ground No. 1& 2 of the

ITA 254/IND/2017[2008-09]Status: DisposedITAT Indore10 Jan 2019AY 2008-09

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Boradassessment Year 2008-09 Dcit-3(1), Kumari Sheetal Garg, Indore Vs. 8/2, New Palasia, Indore (Appellant) (Respondent ) Pan No.Afhpg9179G Revenue By Shri K.C. Selvamani, Sr.Dr Assessee By Shri S.S. Solanki, Ca Date Of Hearing 07.01.2019 Date Of Pronouncement 10.01.2019 O R D E R

Section 143(3)Section 147Section 2Section 53ASection 54F

transfer from hands of assessee was date of registration i.e. 10.04.2007 while, the assessee relinquished here rights vide sale agreement dated 14.12.2006 in favour of Shri Vinay Chajlani and Smt. Sunita Chajlani and enjoying the said rights Shri Vinay Chajlani & Smt. Sun ita Chajlani sold the property to M/s. Honeywell Property P. Ltd. at higher price than that is mentioned

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)

143(3) read with section 144C of the Income-tax Act, 1961 ["hereinafter referred to as "the Act"] on the following Page 1 of 22 Cummins Technologies India P. ltd. Page 2 of 22 grounds which are independent of and without prejudice to each other. 1. General Ground: Transfer pricing

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

143(3) of the Act by making certain additions. Against these additions, the assessee went in appeal before the first appellate authority, but partly succeeded. Against decisions of the ld.CIT(A)both the Century 21 Malls P.Ltd Vs. ACIT (Indore Bench) – (9 Cross-Appeals) 3 Revenue and assessee are before the Tribunal. First we take up appeals for the Asst.Year

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

143(3) of the Act by making certain additions. Against these additions, the assessee went in appeal before the first appellate authority, but partly succeeded. Against decisions of the ld.CIT(A)both the Century 21 Malls P.Ltd Vs. ACIT (Indore Bench) – (9 Cross-Appeals) 3 Revenue and assessee are before the Tribunal. First we take up appeals for the Asst.Year