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10 results for “transfer pricing”+ Section 154clear

Sorted by relevance

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Key Topics

Section 50C12Section 1478Section 1488Addition to Income8Section 143(3)7Section 43(1)5Long Term Capital Gains3Reassessment3Section 253

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

2
Section 2502
Section 246A2
Bogus/Accommodation Entry2

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)

section 271(1)(c) without considering the fact that transfer 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

ASSISTANT COMMISSIONER OF INCOME TAX, INDORE vs. COMMANDER INDUSTRIES PRIVATE LIMITED, INDORE

In the result, the appeal of the revenue and CO of assessee are dismissed

ITA 24/IND/2024[2020-21]Status: DisposedITAT Indore25 Oct 2024AY 2020-21
Section 139(1)Section 142(1)Section 143(2)Section 32(1)Section 43(1)Section 43(6)(c)Section 47

154 (SC)\n(iii)PCIT vs. Zydus Welness Ltd. 87 taxmann.com 82 (Guj)\n(iv)CIT vs. RFCL Ltd. 57 taxmann.com 17 (Himachal Pradesh)\n(v)Triune Energy Services P. Itd. vs. DCIT 65 taxmann.com 288 (Delhi HC)\n(vi)B. Raveendran Pillai vs. CIT 194 taxman 477 (Kerala)\n(vii)Desney Broadcasting (India) (P.) Ltd. vs. Principal Commissioner

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

transfer, either at the time of purchase or at the time of sale of share by the appellant, treatment of LTCG as unexplained credit under section 68 of the Act and confirmation thereof by Ld. CIT(A) is wholly unjustified, improper and bad in law. 06) Section 68: Issue: Burden to prove :- That the Commissioner of Income tax (A) erred

SHRI SANJAY DUBEY,BHOPAL vs. THE ITO 1 (2), BHOPAL

In the result, the appeal of assesse in ITANo

ITA 140/IND/2023[2011-12]Status: PendingITAT Indore07 Dec 2023AY 2011-12

Bench: Shri Vijay Pal Rao

Section 143(3)Section 147Section 154Section 50C

154 of the Act respectively for A.Y.2011-12. 2. In the appeal arising from the reassessment order passed u/s 147 r.w. section 143(3) the assessee has raised following grounds of appeal: “1.That the Ld. Lower authority has erred in holding the view that appellant is liable for capital gain tax on forcefully transfer of immovable property by the bank against

SHRI SANJAY DUBEY,BHOPAL vs. THE ITO 1 (2), BHOPAL

In the result, the appeal of assesse in ITANo

ITA 141/IND/2023[2011-12]Status: PendingITAT Indore07 Dec 2023AY 2011-12

Bench: Shri Vijay Pal Rao

Section 143(3)Section 147Section 154Section 50C

154 of the Act respectively for A.Y.2011-12. 2. In the appeal arising from the reassessment order passed u/s 147 r.w. section 143(3) the assessee has raised following grounds of appeal: “1.That the Ld. Lower authority has erred in holding the view that appellant is liable for capital gain tax on forcefully transfer of immovable property by the bank against

SHAILESH KALWADIA (HUF) ,UJJAIN vs. INCOME TAX OFFICER BPL-C-(91)(1), UJJAIN

The appeal of the assessee is allowed for statistical purpose

ITA 160/IND/2026[2013-14]Status: DisposedITAT Indore27 Mar 2026AY 2013-14

Bench: Shri B.M. Biyani & Shri Paresh M Joshi

Section 147Section 246ASection 250Section 253

price of the penny stock company has not been rigged up. The appellant failed to establish that exit providers are not bogus. The appellant grossly failed to prove that the statements given by the entry operators are not correct. Further, during the appellate proceeding, the Appellant could not controvert any of the findings made by the AO in the assessment

SHAILESH KALWADIA (HUF),UJJAIN vs. INCOME TAX OFFICER, BPL-C(91)(1), BHOPAL

The appeal of the assessee is allowed for statistical purpose

ITA 464/IND/2025[2013-14]Status: DisposedITAT Indore27 Mar 2026AY 2013-14

Bench: Shri B.M. Biyani & Shri Paresh M Joshi

Section 147Section 246ASection 250Section 253

price of the penny stock company has not been rigged up. The appellant failed to establish that exit providers are not bogus. The appellant grossly failed to prove that the statements given by the entry operators are not correct. Further, during the appellate proceeding, the Appellant could not controvert any of the findings made by the AO in the assessment

DCIT-4(1), INDORE vs. M/S. YAKSHA INFRASTRUCTURE COM. PVT. LTD., TALOJA, RAIGARH

Appeal is dismissed

ITA 460/IND/2019[2011-12]Status: DisposedITAT Indore14 Mar 2023AY 2011-12

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

For Appellant: Shri Sumit Nema & shri GaganFor Respondent: Shri P. K. Mishra, CIT.D.R
Section 143(3)

transfer of shares by the assessee is in the name of NSIL Infotech Ltd. and NSIL Power Ltd. There is no doubt that such transactions were related to sale of shares of Mid India Steel & Power Ltd. by the assessee to NSIL Infotech Ltd. and NSIL Power Ltd. which took place only in A.Y.2010-2011. The Ld. DR at the time

YAKSHA INFRASTRUCTURE COMPANY (P) LTD. (FORMERLY KNOWN FROLIC REALTY (P) LTD.),MUMBAI vs. DCIT-3(1) , INDORE

Appeal is dismissed

ITA 290/IND/2019[2011-12]Status: DisposedITAT Indore14 Mar 2023AY 2011-12

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

For Appellant: Shri Sumit Nema & shri GaganFor Respondent: Shri P. K. Mishra, CIT.D.R
Section 143(3)

transfer of shares by the assessee is in the name of NSIL Infotech Ltd. and NSIL Power Ltd. There is no doubt that such transactions were related to sale of shares of Mid India Steel & Power Ltd. by the assessee to NSIL Infotech Ltd. and NSIL Power Ltd. which took place only in A.Y.2010-2011. The Ld. DR at the time