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72 results for “transfer pricing”+ Section 147clear

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Key Topics

Section 271D207Section 8097Section 269S83Section 14780Section 143(3)79Addition to Income42Section 80I33Section 271E33Section 14830Deduction

SANJEEV AGRAWAL ,BHOPAL vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL-2, BHOPAL

Appeal is allowed

ITA 38/IND/2024[2017-18]Status: DisposedITAT Indore21 Feb 2025AY 2017-18
Section 131Section 133ASection 139(1)Section 143(3)Section 147Section 148Section 69C

Price Waterhouse & Co Vs. Deputy Commissioner of Income\nTax, Circle-22, ITA No. 1985/Kol2018 Order dated 5/2/2020, it\nwas observed:-\n“11. Therefore, in the light of the aforesaid judicial precedents and other case\nlaws, we note that to initiate reopening of the assessment, the Ld. AO must\nhave 'reason to believe that income chargeable to tax has escaped assessment

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

Showing 1–20 of 72 · Page 1 of 4

27
Disallowance23
Penalty19

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

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 and service providers, whose

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

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 and service providers, whose

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

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 and service providers, whose

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

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 and service providers, whose

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

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 and service providers, whose

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

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 and service providers, whose

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

147 r.w.s 143(3) of the Act, has contended that this issue was not forming part of the ‘reasons to believe' as recorded by the AO for initiating these reopening proceedings, further this issue was categorically examined during the regular assessment proceedings and in fact part of the losses amounting to Rs. 5,44,57,527/-was also disallowed

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

147 r.w.s 143(3) of the Act, has contended that this issue was not forming part of the ‘reasons to believe' as recorded by the AO for initiating these reopening proceedings, further this issue was categorically examined during the regular assessment proceedings and in fact part of the losses amounting to Rs. 5,44,57,527/-was also disallowed

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

147 r.w.s 143(3) of the Act, has contended that this issue was not forming part of the ‘reasons to believe' as recorded by the AO for initiating these reopening proceedings, further this issue was categorically examined during the regular assessment proceedings and in fact part of the losses amounting to Rs. 5,44,57,527/-was also disallowed

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

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 audited books

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

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 audited books

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)

section 65A and 65B of the Indian Evidence Act 1872 providing for admissibility of electronic records as evidence have not been followed. The appellant has also placed reliance on certain decisions wherein, on identical facts, similar addition made have been deleted. 4.2.2 After considering the observation made in the assessment order and also taking into consideration the written submissions

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)

section 65A and 65B of the Indian Evidence Act 1872 providing for admissibility of electronic records as evidence have not been followed. The appellant has also placed reliance on certain decisions wherein, on identical facts, similar addition made have been deleted. 4.2.2 After considering the observation made in the assessment order and also taking into consideration the written submissions

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

147 of the Act on the ground that appellant was indulged in manipulating the share price without any corroborative evidences against her is wholly unjustified, improper and bad in law. 04) Section 68: Issue: long term capital gain That the CIT(A) erred in law in not considering the genuineness of long term capital gam earned by the appellant claimed

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

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

VAISHALI DEVELOPERS AND BUILDERS ,BHOPAL vs. INCOME TAX OFFICER -1(2), BHOPAL

Appeals are allowed

ITA 27/IND/2024[2009-10]Status: DisposedITAT Indore24 Feb 2025AY 2009-10

Bench: Shri B.M. Biyani & Shri Udayan Das Gupta

Section 143(3)Section 80

section 80-IB(10), the entirety of project including development of infrastructure must be undertaken by assessee. According to Ld. DR, ‘entire project’ would mean development as a cohesive unit which includes the construction of houses with development of essential amenities. In the case of assessee, the buyers have first acquired ownership of plots from assessee through registered Sale-Deeds

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

Transfer Pricing Officer, as the case may be, had been the subject-matter of any appeal filed on or before or after the 1st day of June, 1988, the powers of the Principal Commissioner or Commissioner under this sub-section shall extend and shall be deemed always to have extended to such matters as had not been considered and decided

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