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233 results for “transfer pricing”+ Section 143(1)clear

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Key Topics

Section 143(3)110Section 26372Addition to Income53Section 10(38)52Section 6834Exemption30Section 12A27Section 153A27Section 143(2)25

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 233 · Page 1 of 12

...
Long Term Capital Gains24
Section 50C18
Disallowance16

NILIMA KOTHARI,INDORE vs. THE INCOME TAX OFFICER, NATIONAL FACELESS ASSTT. CENTRE, INDORE

In the result appeal of the assessee is allowed as per terms indicated above

ITA 259/IND/2024[2016-17]Status: DisposedITAT Indore20 Sept 2024AY 2016-17

Bench: Shri Manish Boradsmt. Neelima Kothari, Income Tax Officer, 601, N.R.K. Villas, Delhi Vs. 22/2 Manoramaganj, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Adnpk7832J Assessee By Shri S.S. Deshpande, Ar Revenue By Shri Ashish Porwal, Sr.Dr Date Of Hearing 08.08.2024 Date Of Pronouncement 20.09.2024

Section 10(38)Section 147Section 148Section 151Section 68

transfer, either at the time of purchase or at the time of sale of share by the appellant, treatment of LTCG as unexplained credit under section 68 of the Act and confirmation thereof by Ld. CIT(A) is wholly unjustified, improper and bad in law. 06) Section 68: Issue: Burden to prove :- That the Commissioner of Income tax (A) erred

M/S SHREE JAIRAM EDUCATION SOCIETY,BHOPAL vs. PR. CIT (CENTRAL), BHOPAL

In the result, appeal of the assessee in ITANo

ITA 90/IND/2019[-]Status: DisposedITAT Indore13 Oct 2021

Bench: Hon’Ble Rajpal Yadav & Shri Manish Boradvirtual Hearing

Section 12ASection 132Section 143(2)Section 148Section 37

143(3) rws 147 for AY 2010-11. Before Ld. CIT(A), assessee along with other grounds raised the following grounds of appeal – a. Disallowance of expenditure of Rs. 3,52,94,416 and [PB 97, ground no. 3] b. Addition on concealment of fees of Rs. 69,70,505 [PB 98, ground no. 7] Ld. CIT(A) accepted

M/S SHREE JAIRAM EDUCATION SOCIETY,BHOPAL vs. ACIT CENTRAL-II, BHOPAL

In the result, appeal of the assessee in ITANo

ITA 548/IND/2019[2010-11]Status: DisposedITAT Indore13 Oct 2021AY 2010-11

Bench: Hon’Ble Rajpal Yadav & Shri Manish Boradvirtual Hearing

Section 12ASection 132Section 143(2)Section 148Section 37

143(3) rws 147 for AY 2010-11. Before Ld. CIT(A), assessee along with other grounds raised the following grounds of appeal – a. Disallowance of expenditure of Rs. 3,52,94,416 and [PB 97, ground no. 3] b. Addition on concealment of fees of Rs. 69,70,505 [PB 98, ground no. 7] Ld. CIT(A) accepted

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

1,62,04,760/- as disallowance of deduction u/s 80-IC of the Act made in the order u/s 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

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

1,62,04,760/- as disallowance of deduction u/s 80-IC of the Act made in the order u/s 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

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

1,62,04,760/- as disallowance of deduction u/s 80-IC of the Act made in the order u/s 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

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

1,62,04,760/- as disallowance of deduction u/s 80-IC of the Act made in the order u/s 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

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

1,62,04,760/- as disallowance of deduction u/s 80-IC of the Act made in the order u/s 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

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

1,62,04,760/- as disallowance of deduction u/s 80-IC of the Act made in the order u/s 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

THE DCIT-1(1), INDORE vs. M/S. AGRAWAL COAL CORPORATION P. LTD., INDORE

ITA 607/IND/2015[2009-10]Status: DisposedITAT Indore08 Mar 2017AY 2009-10

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

143(1) and were picked up in scrutiny through CASS. On verification of records, the AO observed that the assessee has entered into international transactions as defined u/s 92B. Accordingly, after seeking the prior approval of the CIT-II, Indore, the cases were referred to the Transfer Pricing Officer, Ahmedabad (for short- TPO) to determine the “arm’s length price

THE DCIT1(1), INDORE vs. M/S. AGRAWAL COAL CORPORATION P LTD., INDORE

ITA 622/IND/2015[2010-11]Status: DisposedITAT Indore08 Mar 2017AY 2010-11

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

143(1) and were picked up in scrutiny through CASS. On verification of records, the AO observed that the assessee has entered into international transactions as defined u/s 92B. Accordingly, after seeking the prior approval of the CIT-II, Indore, the cases were referred to the Transfer Pricing Officer, Ahmedabad (for short- TPO) to determine the “arm’s length price

M/S. AGRAWAL COAL CORPORATION P. LTD.,INDORE vs. THE DCIT RANGE 1(1), INDORE

ITA 601/IND/2015[2009-10]Status: DisposedITAT Indore08 Mar 2017AY 2009-10

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

143(1) and were picked up in scrutiny through CASS. On verification of records, the AO observed that the assessee has entered into international transactions as defined u/s 92B. Accordingly, after seeking the prior approval of the CIT-II, Indore, the cases were referred to the Transfer Pricing Officer, Ahmedabad (for short- TPO) to determine the “arm’s length price

M/S. AGRAWAL COAL CORPORATION P. LTD.,INDORE vs. THE DCIT -CIRCLE 1(1), INDORE

ITA 602/IND/2015[2010-11]Status: DisposedITAT Indore08 Mar 2017AY 2010-11

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

143(1) and were picked up in scrutiny through CASS. On verification of records, the AO observed that the assessee has entered into international transactions as defined u/s 92B. Accordingly, after seeking the prior approval of the CIT-II, Indore, the cases were referred to the Transfer Pricing Officer, Ahmedabad (for short- TPO) to determine the “arm’s length price

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

ASSISTANT COMMISSIONER OF INCOME TAX, INDORE vs. COMMANDER INDUSTRIES PRIVATE LIMITED, INDORE

In the result, the appeal of the revenue and CO of assessee are dismissed

ITA 24/IND/2024[2020-21]Status: DisposedITAT Indore25 Oct 2024AY 2020-21
Section 139(1)Section 142(1)Section 143(2)Section 32(1)Section 43(1)Section 43(6)(c)Section 47

143(2) was issued on 29.06.2021. The AO issued show cause notice u/s 142(1) requiring the assessee to submit clarification/show cause as to why disallowance of claim of depreciation on goodwill as\na result of amalgamation/merger should not be made. The assessee filed its reply dated 30.03.2022. The AO noted that the assessee has claimed depreciation @25% of intangible

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

143(3) read with section 144C and 92CA of Income Tax Act,1961(hereinafter referred as of ”the Act”) of the Deputy Commissioner of Income tax- 1(1),Bhopal (hereinafter referred as “the AO”), for the assessment year 2010-11 order dated 13.02.2015 and for the A.Y. 2011-12 order dated 22.02.2016 passed in pursuance of the directions issued

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

143(3) read with section 144C and 92CA of Income Tax Act,1961(hereinafter referred as of ”the Act”) of the Deputy Commissioner of Income tax- 1(1),Bhopal (hereinafter referred as “the AO”), for the assessment year 2010-11 order dated 13.02.2015 and for the A.Y. 2011-12 order dated 22.02.2016 passed in pursuance of the directions issued

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

143(3) read with section 144C and 92CA of Income Tax Act,1961(hereinafter referred as of ”the Act”) of the Deputy Commissioner of Income tax- 1(1),Bhopal (hereinafter referred as “the AO”), for the assessment year 2010-11 order dated 13.02.2015 and for the A.Y. 2011-12 order dated 22.02.2016 passed in pursuance of the directions issued

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

143(3) read with section 144C and 92CA of Income Tax Act,1961(hereinafter referred as of ”the Act”) of the Deputy Commissioner of Income tax- 1(1),Bhopal (hereinafter referred as “the AO”), for the assessment year 2010-11 order dated 13.02.2015 and for the A.Y. 2011-12 order dated 22.02.2016 passed in pursuance of the directions issued