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62 results for “transfer pricing”+ Section 144clear

Sorted by relevance

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Key Topics

Addition to Income57Section 143(3)54Section 6826Section 80I24Section 14722Section 14822Section 32A16Disallowance16Section 26315

M/S. BRIDGESTONE INDIA PVT. LTD.,PUNE vs. THE ACIT NFAC, DELHI

In the result, appeal of assessee is partly allowed

ITA 84/IND/2022[2017-18/]Status: DisposedITAT Indore17 Jul 2023

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanibridgestone India Pvt. Ltd. Acit (Nfac) Plot No.A-43, Phase-Ii, Delhi Midc Chakan, Village Vs. Sawardari, Taluka Khed, Pune (Appellant / Assessee) (Respondent/ Revenue) Pan: Aabcb 2304 E Assessee By Shri Sukhsagar Syal, Ar Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 23.05.2023 Date Of Pronouncement 17.07.2023

Section 143(3)Section 144C(13)Section 144C(5)Section 43(1)

transfer pricing documentation and economic analysis has passed an order dated 30.10.2018 under Section 92CA(3) of the Act determining the "Arm's Length Price" difference of Rs. 41,57,14,9471- in respect of royalty payment of its AE and Rs. 39,63,921/- in respect of international transactions relating to trading activities of the assessee. Thus, total upward

Showing 1–20 of 62 · Page 1 of 4

Section 143(2)13
Survey u/s 133A11
Depreciation9

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)

pricing adjustment has been made on account of difference of opinion, interpretation of provisions of law, etc. and not due to any concealment of or furnishing of inaccurate particulars of income by the Appellant.” 2. The assessee has also filed additional grounds of appeal vide application dated 14th August 2023. The additional grounds of appeal are as under: “Ground

M/S ASHOKA HI-TECH BUILDERS P. LTD.,INDORE vs. THE DCIT (CENTRAL)-1, INDORE

In the result Ground No.1 and 2 of the assessee’s appeal for A

ITA 686/IND/2016[2013-14]Status: DisposedITAT Indore03 Aug 2018AY 2013-14

Bench: Shri Kul Bharat & Shri Manish Borad

Section 132Section 143(3)Section 145Section 153A

transferred 32 of the monies received to the appellant's account. The Developer, M/s JSM Devcon Pvt. Ltd. after considering all the factors has adopted Percentage Completion Method for revenue recognition, which shall be binding on the appellant company as well, as it is dependent on the Developer for all the activities. 4.11 Reliance is also placed on the following

NAVIN KUMAR JAIN,INDORE vs. ITO ACIT DYCIT FACELESS ASSESSMENT, INDORE

In the result, both appeals of the assessee are allowed

ITA 469/IND/2023[2014-15]Status: DisposedITAT Indore29 May 2024AY 2014-15

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

Section 148

transferred to other parties by RTGS etc. The assessee is one of the beneficiaries of the cash deposits. The asseessee had deposited cash of Rs. 50,17,236/-in the account of society and the same was not disclosed in the return of income. Cash deposition in this case remained unexplained.The facts have been examined and found correct. 3. Therefore

NAVIN KUMAR JAIN,INDORE vs. INCOME TAX OFFICER FACELESS ASSESSMENT CENTRE, INDORE

In the result, both appeals of the assessee are allowed

ITA 468/IND/2023[2013-14]Status: DisposedITAT Indore29 May 2024AY 2013-14

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

Section 148

transferred to other parties by RTGS etc. The assessee is one of the beneficiaries of the cash deposits. The asseessee had deposited cash of Rs. 50,17,236/-in the account of society and the same was not disclosed in the return of income. Cash deposition in this case remained unexplained.The facts have been examined and found correct. 3. Therefore

SHRI NARESH MODI (LEGAL HEIR OF LATE SHRI BASANTILAL MODI),INDORE vs. THE ITO 3(2), INDORE

In the result, the appeal of the Assessee in ITANo

ITA 548/IND/2016[2008-09]Status: DisposedITAT Indore31 Jan 2018AY 2008-09

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2008-09

Section 142(1)Section 143(3)Section 144Section 147Section 148Section 50C

144 r.w. section 147 was framed vide order dated 21.03.2014. During the course of assessment no one appeared on behalf of the assessee, therefore, the AO, on the basis of material available on record made addition of Rs.68,66,000/- by invoking the provisions of section 50C of the Act in respect of the sale value of the property

S GANDHI JEWELLERY PRIVATE LIMITED,INDORE vs. PCIT-1, INDORE, INDORE

Appeal is allowed

ITA 311/IND/2024[2017-18]Status: DisposedITAT Indore21 Feb 2025AY 2017-18

Bench: Shri B.M. Biyani & Shri Dinesh Mohan Sinhaassessment Year: 2017-18 S. Gandhi Jewellery Pcit-1, Private Limited, Indore C/O Adv. Hitesh Chimnani, बनाम/ Ug-37 Trade Centre, Vs. 18, South Tukoganj, Indore (Assessee/Appellant) (Revenue/Respondent) Pan: Aamcs1613G Assessee By Shri Hitesh Chimnani, Ar Revenue By Shri Ram Kumar Yadav, Sr. Dr Date Of Hearing 10.02.2025 Date Of Pronouncement 21.02.2025

Section 143(2)Section 143(3)Section 147Section 263

144 of the Act is not only erroneous but also prejudicial to the interest of the revenue as the Assessing Officer has failed to conduct any inquiry and verification which is patently incorrect. 3. That on the facts and in the circumstances of the case and in law, the Ld. PCIT erred in treating the order passed

M/S BHOMIYAJI LAND & FINANCE CO.,DEWAS vs. THE ACIT 1(1), UJJAIN

In the result ground No.3& 4 are dismissed

ITA 263/IND/2013[2006-07]Status: DisposedITAT Indore31 Jan 2018AY 2006-07

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2006-07

Section 133ASection 143(2)

144.]” 3.2.14 As per the provisions of section 145(3), if AO is not satisfied about the correctness of the account he can invoked the provisions of section 145(3). It is held by Hon'ble Supreme Court in the case of CIT vs. A. Krishna Swami Mudliyar (1964) 53 ITR 122 (SC) held that: “ Section 145 does not compel

THE DCIT, 1(1), UJJAIN vs. M/S. BHOOMIYAJI LAND & FINANCE LTD., DEWAS

In the result ground No.3& 4 are dismissed

ITA 634/IND/2014[2010-11]Status: DisposedITAT Indore31 Jan 2018AY 2010-11

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2006-07

Section 133ASection 143(2)

144.]” 3.2.14 As per the provisions of section 145(3), if AO is not satisfied about the correctness of the account he can invoked the provisions of section 145(3). It is held by Hon'ble Supreme Court in the case of CIT vs. A. Krishna Swami Mudliyar (1964) 53 ITR 122 (SC) held that: “ Section 145 does not compel

THE DCIT, 1(1), UJJAIN vs. M/S BHOOMIYAJI LAND & FINANCE CO.,, DEWAS

In the result ground No.3& 4 are dismissed

ITA 137/IND/2013[2008-09]Status: DisposedITAT Indore31 Jan 2018AY 2008-09

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2006-07

Section 133ASection 143(2)

144.]” 3.2.14 As per the provisions of section 145(3), if AO is not satisfied about the correctness of the account he can invoked the provisions of section 145(3). It is held by Hon'ble Supreme Court in the case of CIT vs. A. Krishna Swami Mudliyar (1964) 53 ITR 122 (SC) held that: “ Section 145 does not compel

M/S BHOOMIYAJI LAND & FINANCE CO.,DEWAS vs. THE ITO, DEWAS

In the result ground No.3& 4 are dismissed

ITA 142/IND/2013[2008-09]Status: DisposedITAT Indore31 Jan 2018AY 2008-09

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2006-07

Section 133ASection 143(2)

144.]” 3.2.14 As per the provisions of section 145(3), if AO is not satisfied about the correctness of the account he can invoked the provisions of section 145(3). It is held by Hon'ble Supreme Court in the case of CIT vs. A. Krishna Swami Mudliyar (1964) 53 ITR 122 (SC) held that: “ Section 145 does not compel

THE DCIT, 1(1), UJJAIN vs. M/S. BHOOMIYAJI LAND & FINANCE CO.,, DEWAS

In the result ground No.3& 4 are dismissed

ITA 412/IND/2013[2007-08]Status: DisposedITAT Indore31 Jan 2018AY 2007-08

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2006-07

Section 133ASection 143(2)

144.]” 3.2.14 As per the provisions of section 145(3), if AO is not satisfied about the correctness of the account he can invoked the provisions of section 145(3). It is held by Hon'ble Supreme Court in the case of CIT vs. A. Krishna Swami Mudliyar (1964) 53 ITR 122 (SC) held that: “ Section 145 does not compel

THE DCIT, 1(1), UJJAIN vs. M/S. BHOOMIYAJI LAND & FINANCE CO.,, DEWAS

In the result ground No.3& 4 are dismissed

ITA 411/IND/2013[2006-07]Status: DisposedITAT Indore31 Jan 2018AY 2006-07

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2006-07

Section 133ASection 143(2)

144.]” 3.2.14 As per the provisions of section 145(3), if AO is not satisfied about the correctness of the account he can invoked the provisions of section 145(3). It is held by Hon'ble Supreme Court in the case of CIT vs. A. Krishna Swami Mudliyar (1964) 53 ITR 122 (SC) held that: “ Section 145 does not compel

M/S. BHOMIYAJI LAND & FINANCE CO.,DEWAS vs. THE ITO, DEWAS

In the result ground No.3& 4 are dismissed

ITA 490/IND/2013[2007-08]Status: DisposedITAT Indore31 Jan 2018AY 2007-08

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2006-07

Section 133ASection 143(2)

144.]” 3.2.14 As per the provisions of section 145(3), if AO is not satisfied about the correctness of the account he can invoked the provisions of section 145(3). It is held by Hon'ble Supreme Court in the case of CIT vs. A. Krishna Swami Mudliyar (1964) 53 ITR 122 (SC) held that: “ Section 145 does not compel

RUPESH VYAS,INDORE vs. THE ACIT3(1), INDORE, INDORE

In the result, this appeal of assessee is dismissed

ITA 50/IND/2020[150-16]Status: DisposedITAT Indore06 Dec 2022

Bench: Shri T.R. Senthil Kumar & Shri B.M. Biyani

Section 10(38)Section 143(3)Section 68Section 69C

transfer of long term 'capital asset' was not includible in total income of the assessee in view of section 10(38) of the Act. 2.2. That the learned Commissioner of Income Tax (Appeals) has failed to appreciate the evidence tendered by the appellant to support the claim of sale of shares and hence, findings mechanically recorded on borrowed inference

RUPESH VYAS,INDORE vs. THE ACIT3(1), INDORE, INDORE

In the result, this appeal of assessee is dismissed

ITA 909/IND/2018[2014-15]Status: DisposedITAT Indore07 Dec 2022AY 2014-15

Bench: Ms. Suchitra Kamble & Shri B.M. Biyani

Section 10(38)Section 143(3)Section 68Section 69C

transfer of long term 'capital asset' was not includible in total income of the assessee in view of section 10(38) of the Act. 2.2. That the learned Commissioner of Income Tax (Appeals) has failed to appreciate the evidence tendered by the appellant to support the claim of sale of shares and hence, findings mechanically recorded on borrowed inference

SHRI PRADEEP MAHESHWARI HUF,INDORE vs. THE ACIT 3(1), INDORE

In the result I.T.A.No.315/Ind/2012& I

ITA 53/IND/2014[2008-09]Status: DisposedITAT Indore30 Oct 2018AY 2008-09

Bench: Shri Kul Bharat & Shri Manish Borad

Section 10(38)Section 143(3)Section 68

144 of the Evidence Act." (b) 'Attar Singh Gurmukh Singh v. ITO 191 ITR 667(SC) wherein, while interpreting the provisions of section 40A(3), it was held that "In interpreting a taxing statute, the court cannot be oblivious of the proliferation of black money which is under circulation in our country."' 4.3.3; AO's finding that

SMT. ANNAPURNA MAHESHWARI,INDORE vs. THE ITO-4(1), INDORE

In the result I.T.A.No.315/Ind/2012& I

ITA 252/IND/2016[2010-11]Status: DisposedITAT Indore30 Oct 2018AY 2010-11

Bench: Shri Kul Bharat & Shri Manish Borad

Section 10(38)Section 143(3)Section 68

144 of the Evidence Act." (b) 'Attar Singh Gurmukh Singh v. ITO 191 ITR 667(SC) wherein, while interpreting the provisions of section 40A(3), it was held that "In interpreting a taxing statute, the court cannot be oblivious of the proliferation of black money which is under circulation in our country."' 4.3.3; AO's finding that

SMT. ANNAPURNA MAHESHWARI,INDORE vs. THE ACIT, 4(1), INDORE

In the result I.T.A.No.315/Ind/2012& I

ITA 315/IND/2012[2008-09]Status: DisposedITAT Indore30 Oct 2018AY 2008-09

Bench: Shri Kul Bharat & Shri Manish Borad

Section 10(38)Section 143(3)Section 68

144 of the Evidence Act." (b) 'Attar Singh Gurmukh Singh v. ITO 191 ITR 667(SC) wherein, while interpreting the provisions of section 40A(3), it was held that "In interpreting a taxing statute, the court cannot be oblivious of the proliferation of black money which is under circulation in our country."' 4.3.3; AO's finding that

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

144, in case he is not satisfied about the correctness or completeness of the assessee or where the method of accounting have not been regularly followed by the assessee, Once the assessee followed accounting regularly the Assessing Officer is bound to assess the income of the assessee on the basis of such method of accounting On perusal of the provision