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102 results for “transfer pricing”+ Section 143(3)clear

Sorted by relevance

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Key Topics

Section 143(3)165Section 8095Addition to Income63Section 14757Section 12A51Section 10(38)43Section 26342Section 153A36Section 143(2)34Exemption

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 102 · Page 1 of 6

34
Deduction25
Disallowance23

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

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 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

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 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 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

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

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

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

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

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

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

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

M/S. S.R. FERRO ALLOYS,JHABUA vs. THE PCIT, BHOPAL

In the result, the appeal of assessee is allowed

ITA 148/IND/2021[2015-16]Status: DisposedITAT Indore09 Nov 2023AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanis.R. Ferro Alloys Pr. Cit, Central 9, Siddheswar Colony Bhopal Vs. Jhabua (Appellant / Assessee) (Revenue) Pan: Abhfs7377Q Appellant By Shri Sumit Nema, Sr. Adv. & Gagan Tiwari, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 12.10.2023 Date Of Pronouncement 09.11.2023

Section 263

price. A method of accounting adopted by the trader consistently and regularly cannot be discarded by departmental authorities on the view that he should have adopted a different method of keeping accounts or of valuation. The method of accounting regularly employed may be discarded only, if, in the opinion of taxing authorities, income of the trade cannot be property Page

M/S RANA & JOSHI BUILDTECH P LTD,INDORE vs. THE PCIT-1, BHOPAL

In the result, the appeal of the assessee is allowed

ITA 229/IND/2023[2015-16]Status: DisposedITAT Indore26 Sept 2024AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S. Rana & Joshi Buildtech Pr. Cit-1 Pvt. Ltd. Bhopal (Formerly Known As M/S Rana Buildtech Pvt. Ltd. ) Vs. 218 Civil Lines, Below Dainik Bhaskar Office Vidisha (Appellant / Assessee) (Respondent/ Revenue) Pan: Aafcr9858P Assessee By Shri S.N. Agrawal Ar Revenue By Shri Ram Kumar Yadav, Cit-Dr Date Of Hearing 11.09.2024 Date Of Pronouncement 26 .09.2024

Section 143(3)Section 263Section 271E

3) of the Act and subsequently the case was transferred to DCIT. 11. We have considered rival submissions as well as relevant material on record. The assessee has challenged the validity of the initiation of the scrutiny assessment on the ground that notice u/s 143(2) was issued by the ITO 4(1) Bhopal was not having jurisdiction over

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

143(3) having regard to TPO’s order u/s 92CA(3) and DRP’s order u/s 144C(5). Aggrieved by order of AO, the assessee has come in this appeal. 4. The grounds raised by assessee are as under: “1. The order of the AO passed pursuant to the order of the TPO and the directions issued

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

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