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93 results for “transfer pricing”+ Section 148(2)clear

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Key Topics

Section 143(3)79Addition to Income71Section 14765Section 8042Section 14841Disallowance36Section 6834Section 80I24Deduction20Section 143(2)

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

2 Smt. Nilima Kothari was resumed in 2016. There being no other documents or evidence to reveal that the income chargeable to tax had escaped assessment, proceedings initiated under section 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

Showing 1–20 of 93 · Page 1 of 5

16
Section 32A16
Reopening of Assessment15

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

price than that is mentioned in Agreement with the assessee. 3. Whether on the facts and in the circumstances of the case Ld. CIT(A) has erred in holding that reopening is not valid while the copy of agreement dated 14.12.2006 was not submitted by assessee during the course of assessment proceedings hence, the facts of the agreement

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

148 after expiry of four years from end of assessment- year. Now, in this circumstance, the assessee is pressing the bar imposed in first proviso to section 147 according to which the AO cannot take action against assessee unless there is a case of assessee’s failure to disclose fully and truly all material facts necessary for assessment. The proviso

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

148 after expiry of four years from end of assessment- year. Now, in this circumstance, the assessee is pressing the bar imposed in first proviso to section 147 according to which the AO cannot take action against assessee unless there is a case of assessee’s failure to disclose fully and truly all material facts necessary for assessment. The proviso

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

148 after expiry of four years from end of assessment- year. Now, in this circumstance, the assessee is pressing the bar imposed in first proviso to section 147 according to which the AO cannot take action against assessee unless there is a case of assessee’s failure to disclose fully and truly all material facts necessary for assessment. The proviso

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

148 after expiry of four years from end of assessment- year. Now, in this circumstance, the assessee is pressing the bar imposed in first proviso to section 147 according to which the AO cannot take action against assessee unless there is a case of assessee’s failure to disclose fully and truly all material facts necessary for assessment. The proviso

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

148 after expiry of four years from end of assessment- year. Now, in this circumstance, the assessee is pressing the bar imposed in first proviso to section 147 according to which the AO cannot take action against assessee unless there is a case of assessee’s failure to disclose fully and truly all material facts necessary for assessment. The proviso

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

148 after expiry of four years from end of assessment- year. Now, in this circumstance, the assessee is pressing the bar imposed in first proviso to section 147 according to which the AO cannot take action against assessee unless there is a case of assessee’s failure to disclose fully and truly all material facts necessary for assessment. The proviso

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

148 dated 28.03.2017 are unlawful, bad in law and without jurisdiction hence the assessment made be kindly cancelled. 2. That on the facts & in the circumstances of the case and in law, the learned lower authorities erred and in not justified in assessing the income of the assessee as the income from business and profession

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

148 dated 28.03.2017 are unlawful, bad in law and without jurisdiction hence the assessment made be kindly cancelled. 2. That on the facts & in the circumstances of the case and in law, the learned lower authorities erred and in not justified in assessing the income of the assessee as the income from business and profession

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

148 ITR 774 etc. as per submission made before the TPO in support of his contention. 6.4. The Ld. D.R. relaying on the orders of the TPO/ DRP submitted that ITAT order for A.Y. 1999-2000 to 2002-03 dtd. 09.04.2010 is passed before the amendment in Finance Act, 2010. Further the order Page 55 of 84 M/s. Andritz Hydro

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

148 ITR 774 etc. as per submission made before the TPO in support of his contention. 6.4. The Ld. D.R. relaying on the orders of the TPO/ DRP submitted that ITAT order for A.Y. 1999-2000 to 2002-03 dtd. 09.04.2010 is passed before the amendment in Finance Act, 2010. Further the order Page 55 of 84 M/s. Andritz Hydro

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

148 ITR 774 etc. as per submission made before the TPO in support of his contention. 6.4. The Ld. D.R. relaying on the orders of the TPO/ DRP submitted that ITAT order for A.Y. 1999-2000 to 2002-03 dtd. 09.04.2010 is passed before the amendment in Finance Act, 2010. Further the order Page 55 of 84 M/s. Andritz Hydro

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

148 ITR 774 etc. as per submission made before the TPO in support of his contention. 6.4. The Ld. D.R. relaying on the orders of the TPO/ DRP submitted that ITAT order for A.Y. 1999-2000 to 2002-03 dtd. 09.04.2010 is passed before the amendment in Finance Act, 2010. Further the order Page 55 of 84 M/s. Andritz Hydro

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

148 of the Act and on the basis of the same set of analysis of trade data and enquiries of the brokers conducted by the Investigation Wing Ahmedabad and the losses incurred by the assessee in commodity transactions conducted on the NMCE platform were disallowed. The disallowances were deleted in the first appeal and the department filed second appeal before

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

148 of the Act and on the basis of the same set of analysis of trade data and enquiries of the brokers conducted by the Investigation Wing Ahmedabad and the losses incurred by the assessee in commodity transactions conducted on the NMCE platform were disallowed. The disallowances were deleted in the first appeal and the department filed second appeal before

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

148 of the Act and on the basis of the same set of analysis of trade data and enquiries of the brokers conducted by the Investigation Wing Ahmedabad and the losses incurred by the assessee in commodity transactions conducted on the NMCE platform were disallowed. The disallowances were deleted in the first appeal and the department filed second appeal before

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)

2 8 Data analysis of the transactions undertaken by the appellant. 3 8.1 Details analysis of the trades found as a result of search and survey operations. 4 8.1 NMCE data and PAN field segregation. 5 8.4 Penalties levied by NMCE on the brokers. Cross Objection Nos.5 & 6/Ind/2020 Assessment Years: 2012-13 & 2015-16 6 8.5 Enquires conducted with regard

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)

2 8 Data analysis of the transactions undertaken by the appellant. 3 8.1 Details analysis of the trades found as a result of search and survey operations. 4 8.1 NMCE data and PAN field segregation. 5 8.4 Penalties levied by NMCE on the brokers. Cross Objection Nos.5 & 6/Ind/2020 Assessment Years: 2012-13 & 2015-16 6 8.5 Enquires conducted with regard

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