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75 results for “transfer pricing”+ Section 153(4)clear

Sorted by relevance

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Key Topics

Section 271D207Section 269S83Section 143(3)47Addition to Income43Section 271E33Section 153A26Section 80I26Penalty26Disallowance19

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

Transfer Pricing officer under section 92CA of the Income Tax Act, 1961 by the Assessing Officer was illegal, bad in law being contrary to the binding Instruction No. 3/2003 as the quantum of the international transaction is below Rs.5 crore. 2.That on the facts and circumstances of the case and in law, the final assessment order passed

Showing 1–20 of 75 · Page 1 of 4

Section 14818
Section 14716
Reopening of Assessment9

DILIP BUILDCON LTD.,BHOPAL vs. DCIT (CENTRAL)-1, BHOPAL

In the result, revenue’s appeal for A

ITA 820/IND/2019[2016-17]Status: DisposedITAT Indore27 Jan 2022AY 2016-17

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&

Section 143(3)Section 147Section 148Section 32(1)(iia)Section 32ASection 80I

Transfer the project highway to MPRDC upon termination of the agreement in accordance with the provision thereof. 5 Employment of “The Concessionaire shall ensure that Article 5.5 96 trained the personal engaged by it in the at internal performance of its obligation under this personnel’s page 22 of agreement are at all time properly the trained for their respective

DILIP BUILDCON LTD.,BHOPAL vs. DCIT (CENTRAL)-1, BHOPAL

In the result, revenue’s appeal for A

ITA 819/IND/2019[2015-16]Status: DisposedITAT Indore27 Jan 2022AY 2015-16

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&

Section 143(3)Section 147Section 148Section 32(1)(iia)Section 32ASection 80I

Transfer the project highway to MPRDC upon termination of the agreement in accordance with the provision thereof. 5 Employment of “The Concessionaire shall ensure that Article 5.5 96 trained the personal engaged by it in the at internal performance of its obligation under this personnel’s page 22 of agreement are at all time properly the trained for their respective

DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL)-1, BHOPAL vs. DILIP BUILDCON LIMITED, BHOPAL

In the result, revenue’s appeal for A

ITA 816/IND/2018[14-15]Status: DisposedITAT Indore27 Jan 2022

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&

Section 143(3)Section 147Section 148Section 32(1)(iia)Section 32ASection 80I

Transfer the project highway to MPRDC upon termination of the agreement in accordance with the provision thereof. 5 Employment of “The Concessionaire shall ensure that Article 5.5 96 trained the personal engaged by it in the at internal performance of its obligation under this personnel’s page 22 of agreement are at all time properly the trained for their respective

DILIP BUILDCON LIMITED,BHOPAL vs. DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL)-1, BHOPAL

In the result, revenue’s appeal for A

ITA 782/IND/2018[2014-15]Status: DisposedITAT Indore27 Jan 2022AY 2014-15

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&

Section 143(3)Section 147Section 148Section 32(1)(iia)Section 32ASection 80I

Transfer the project highway to MPRDC upon termination of the agreement in accordance with the provision thereof. 5 Employment of “The Concessionaire shall ensure that Article 5.5 96 trained the personal engaged by it in the at internal performance of its obligation under this personnel’s page 22 of agreement are at all time properly the trained for their respective

DCIT (CENTRAL)-1, BHOPAL vs. DILIP BUILDCON LTD., BHOPAL

In the result, revenue’s appeal for A

ITA 881/IND/2019[2015-16]Status: DisposedITAT Indore27 Jan 2022AY 2015-16

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&

Section 143(3)Section 147Section 148Section 32(1)(iia)Section 32ASection 80I

Transfer the project highway to MPRDC upon termination of the agreement in accordance with the provision thereof. 5 Employment of “The Concessionaire shall ensure that Article 5.5 96 trained the personal engaged by it in the at internal performance of its obligation under this personnel’s page 22 of agreement are at all time properly the trained for their respective

SHRI DILIP BUILDCON LTD,BHOPAL vs. DCIT CENTRAL -1, BHOPAL

In the result, revenue’s appeal for A

ITA 197/IND/2020[2017-18]Status: DisposedITAT Indore27 Jan 2022AY 2017-18

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&

Section 143(3)Section 147Section 148Section 32(1)(iia)Section 32ASection 80I

Transfer the project highway to MPRDC upon termination of the agreement in accordance with the provision thereof. 5 Employment of “The Concessionaire shall ensure that Article 5.5 96 trained the personal engaged by it in the at internal performance of its obligation under this personnel’s page 22 of agreement are at all time properly the trained for their respective

DCIT (CENTRAL)-1, BHOPAL vs. DILIP BUILDCON LTD., BHOPAL

In the result, revenue’s appeal for A

ITA 882/IND/2019[2016-17]Status: DisposedITAT Indore27 Jan 2022AY 2016-17

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&

Section 143(3)Section 147Section 148Section 32(1)(iia)Section 32ASection 80I

Transfer the project highway to MPRDC upon termination of the agreement in accordance with the provision thereof. 5 Employment of “The Concessionaire shall ensure that Article 5.5 96 trained the personal engaged by it in the at internal performance of its obligation under this personnel’s page 22 of agreement are at all time properly the trained for their respective

THED CIT ,CENTRAL-1, BHOPAL vs. M/S DILIP BUILDCON LTD, BHOPAL

In the result, revenue’s appeal for A

ITA 290/IND/2020[2017-18]Status: DisposedITAT Indore27 Jan 2022AY 2017-18

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&

Section 143(3)Section 147Section 148Section 32(1)(iia)Section 32ASection 80I

Transfer the project highway to MPRDC upon termination of the agreement in accordance with the provision thereof. 5 Employment of “The Concessionaire shall ensure that Article 5.5 96 trained the personal engaged by it in the at internal performance of its obligation under this personnel’s page 22 of agreement are at all time properly the trained for their respective

DEPUTY COMMISSIONER OF INCOME TAX -5(1), INDORE vs. M/S SUNDERDEEP CONSTRUCTIONS PVT. LTD. , INDORE

In the result both the appeals of the revenue vide ITA No

ITA 784/IND/2018[2010-11]Status: DisposedITAT Indore09 Mar 2021AY 2010-11

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Borad

Section 143(2)Section 143(3)

153(6)(i) and section 150(1) also fortifies the contention of the assessee to have the direction of the Hon’ble Bench to re-compute the total income of AY 2015-16 and / or AY 2013-14, as the case may be, so as to bring to charge the amount of Rs. 39,21,275/- only once. The combined

DEPUTY COMMISSIONER OF INCOME TAX -5(1), INDORE vs. M/S SUNDERDEEP CONSTRUCTIONS PVT. LTD. , INDORE

In the result both the appeals of the revenue vide ITA No

ITA 786/IND/2018[2013-14]Status: DisposedITAT Indore09 Mar 2021AY 2013-14

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Borad

Section 143(2)Section 143(3)

153(6)(i) and section 150(1) also fortifies the contention of the assessee to have the direction of the Hon’ble Bench to re-compute the total income of AY 2015-16 and / or AY 2013-14, as the case may be, so as to bring to charge the amount of Rs. 39,21,275/- only once. The combined

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

153 A of the I. T. Act while deleting the additions , of Rs. 2,36,839/-and Rs. 10,697/-. 8. Whether on the facts and in the circumstances of the case, the Ld. CIT (A) has erred in law in not appreciating the Circular No. 7 of 2003 dated: 05.09.2003 issued by the CBDT while deleting the additions

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

153 A of the I. T. Act while deleting the additions , of Rs. 2,36,839/-and Rs. 10,697/-. 8. Whether on the facts and in the circumstances of the case, the Ld. CIT (A) has erred in law in not appreciating the Circular No. 7 of 2003 dated: 05.09.2003 issued by the CBDT while deleting the additions

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

153 A of the I. T. Act while deleting the additions , of Rs. 2,36,839/-and Rs. 10,697/-. 8. Whether on the facts and in the circumstances of the case, the Ld. CIT (A) has erred in law in not appreciating the Circular No. 7 of 2003 dated: 05.09.2003 issued by the CBDT while deleting the additions

AG-8 VENTURES LTD.,BHOPAL vs. ACIT, CENTRAL-1, BHOPAL

ITA 923/IND/2019[2014-15]Status: DisposedITAT Indore16 Feb 2021AY 2014-15

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Borad

Section 132Section 133ASection 143(3)Section 14ASection 153ASection 271(1)(c)Section 271ASection 40A(3)Section 80I

4. The appellant carves leave, to add, to alter and/ or to modify the grounds of appeal on or before the date of hearing. 6. We will first take the revenue’s appeals year-wise and if common grounds are raised for multiple years, same will be dealt together. IT(SS)A No.83

AG-8 VENTURES LTD.,BHOPAL vs. ACIT, CENTRAL-1, BHOPAL

ITA 922/IND/2019[2013-14]Status: DisposedITAT Indore16 Feb 2021AY 2013-14

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Borad

Section 132Section 133ASection 143(3)Section 14ASection 153ASection 271(1)(c)Section 271ASection 40A(3)Section 80I

4. The appellant carves leave, to add, to alter and/ or to modify the grounds of appeal on or before the date of hearing. 6. We will first take the revenue’s appeals year-wise and if common grounds are raised for multiple years, same will be dealt together. IT(SS)A No.83

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

ACIT(CENTRAL)-1, INDORE vs. SHRI PUNIT AGRAWAL, MHOW

Appeals are dismissed

ITA 788/IND/2019[2010-11]Status: DisposedITAT Indore31 Jan 2024AY 2010-11

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

Section 132Section 153ASection 269SSection 269TSection 271DSection 271E

transferred from one side to another, addition under section 69C were not sustainable. Hon'ble Supreme Court in the case of Pr. CIT Vs. Vinita Chaurasia [2018] 98 Taxman.com 468 (SC) arising out of Order of HC in CIT Vs.VinitaChaurasia [2017] 82 Taxmann.com 153 dismissed the departmental SLP and affirm the very principle again that when a addition was made

ACIT(CENTRAL)-1, INDORE vs. SHRI PUNIT AGRAWAL, MHOW

Appeals are dismissed

ITA 787/IND/2019[2009-10]Status: DisposedITAT Indore31 Jan 2024AY 2009-10

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

Section 132Section 153ASection 269SSection 269TSection 271DSection 271E

transferred from one side to another, addition under section 69C were not sustainable. Hon'ble Supreme Court in the case of Pr. CIT Vs. Vinita Chaurasia [2018] 98 Taxman.com 468 (SC) arising out of Order of HC in CIT Vs.VinitaChaurasia [2017] 82 Taxmann.com 153 dismissed the departmental SLP and affirm the very principle again that when a addition was made

ACIT(CENTRAL)-1, INDORE vs. SHRI PUNIT AGRAWAL, MHOW

Appeals are dismissed

ITA 790/IND/2019[2009-10]Status: DisposedITAT Indore31 Jan 2024AY 2009-10

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

Section 132Section 153ASection 269SSection 269TSection 271DSection 271E

transferred from one side to another, addition under section 69C were not sustainable. Hon'ble Supreme Court in the case of Pr. CIT Vs. Vinita Chaurasia [2018] 98 Taxman.com 468 (SC) arising out of Order of HC in CIT Vs.VinitaChaurasia [2017] 82 Taxmann.com 153 dismissed the departmental SLP and affirm the very principle again that when a addition was made