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9 results for “transfer pricing”+ Section 182clear

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Key Topics

Section 194H20Section 201(1)14Section 194J14Section 26311Section 143(3)7Section 10A5Deduction5TDS5Revision u/s 2634Section 194

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)

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 2023. The additional grounds of appeal are as under: “Ground

M/S RANA & JOSHI BUILDTECH P LTD,INDORE vs. THE PCIT-1, BHOPAL

3
Section 144C2
Limitation/Time-bar2

In the result, the appeal of the assessee is allowed

ITA 229/IND/2023[2015-16]Status: DisposedITAT Indore26 Sept 2024AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S. Rana & Joshi Buildtech Pr. Cit-1 Pvt. Ltd. Bhopal (Formerly Known As M/S Rana Buildtech Pvt. Ltd. ) Vs. 218 Civil Lines, Below Dainik Bhaskar Office Vidisha (Appellant / Assessee) (Respondent/ Revenue) Pan: Aafcr9858P Assessee By Shri S.N. Agrawal Ar Revenue By Shri Ram Kumar Yadav, Cit-Dr Date Of Hearing 11.09.2024 Date Of Pronouncement 26 .09.2024

Section 143(3)Section 263Section 271E

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, 198810], 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

M/S. IDEA CELLULAR LIMITED,INDORE vs. THE DCIT (TDS), INDORE

Appeals are allowed

ITA 111/IND/2015[2013-14 (Quarter 4)]Status: DisposedITAT Indore01 Aug 2024

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

Section 194Section 194HSection 194JSection 201(1)

182 which was affirmed by the Supreme Court, that mere custody or possession of equipment without effective control can only result in use of the equipment whereas a right to use the equipment implies control over the equipment. We do not think that such distinction has any legal basis. In the case of Rashtriya Ispat Nigam Ltd. (supra), what fell

M/S. IDEA CELLULAR LIMITED,INDORE vs. THE DCIT (TDS), INDORE

Appeals are allowed

ITA 109/IND/2015[2012-13]Status: DisposedITAT Indore01 Aug 2024AY 2012-13

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

Section 194Section 194HSection 194JSection 201(1)

182 which was affirmed by the Supreme Court, that mere custody or possession of equipment without effective control can only result in use of the equipment whereas a right to use the equipment implies control over the equipment. We do not think that such distinction has any legal basis. In the case of Rashtriya Ispat Nigam Ltd. (supra), what fell

M/S. IDEA CELLULAR LIMITED,INDORE vs. THE DCIT (TDS), INDORE

Appeals are allowed

ITA 110/IND/2015[2013-14 (for first three quarter)]Status: DisposedITAT Indore01 Aug 2024

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

Section 194Section 194HSection 194JSection 201(1)

182 which was affirmed by the Supreme Court, that mere custody or possession of equipment without effective control can only result in use of the equipment whereas a right to use the equipment implies control over the equipment. We do not think that such distinction has any legal basis. In the case of Rashtriya Ispat Nigam Ltd. (supra), what fell

M/S. IDEA CELLULAR LIMITED,INDORE vs. THE CIT (TDS), BHOPAL

ITA 415/IND/2014[2010-11]Status: DisposedITAT Indore23 Apr 2024AY 2010-11

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S Vodafone Idea Ltd. Cit (Tds), बनाम/ (Formerly M/S Idea Bhopal Vs. Cellular Ltd.), 139-140, Electronics Complex, Pardeshipura, Indore (Assessee/Appellant) (Revenue/Respondent) M/S Vodafone Idea Ltd. Dcit/Jcit (Tds), बनाम/ (Formerly M/S Idea Indore Vs. Cellular Ltd.), 139-140, Electronics Complex, Pardeshipura, Indore (Assessee/Appellant) (Revenue/Respondent)

Section 194HSection 194JSection 201Section 201(1)Section 250Section 254(2)Section 263

182 which was affirmed by the Supreme Court, that mere custody or possession of equipment without effective control can only result in use of the equipment whereas a right to use the equipment implies control over the equipment. We do not think that such distinction has any legal basis. In the case of Rashtriya Ispat Nigam Ltd. (supra), what fell

IDEA CELLULAR LIMITED,INDORE vs. DCIT TDS, INDORE

ITA 265/IND/2018[2010-11]Status: DisposedITAT Indore23 Apr 2024AY 2010-11

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S Vodafone Idea Ltd. Cit (Tds), बनाम/ (Formerly M/S Idea Bhopal Vs. Cellular Ltd.), 139-140, Electronics Complex, Pardeshipura, Indore (Assessee/Appellant) (Revenue/Respondent) M/S Vodafone Idea Ltd. Dcit/Jcit (Tds), बनाम/ (Formerly M/S Idea Indore Vs. Cellular Ltd.), 139-140, Electronics Complex, Pardeshipura, Indore (Assessee/Appellant) (Revenue/Respondent)

Section 194HSection 194JSection 201Section 201(1)Section 250Section 254(2)Section 263

182 which was affirmed by the Supreme Court, that mere custody or possession of equipment without effective control can only result in use of the equipment whereas a right to use the equipment implies control over the equipment. We do not think that such distinction has any legal basis. In the case of Rashtriya Ispat Nigam Ltd. (supra), what fell

SEWA SAHKARI SAMMITTEE MARYADIT,BEED, MUNDI KHANDWA vs. PCIT-1, INDORE

In the result, appeal by the assesse is allowed

ITA 44/IND/2022[2016-17]Status: DisposedITAT Indore30 Oct 2023AY 2016-17

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanisewa Sahkari Sammittee Pr. Cit-2 Maryadit Beed Indore Vs. Beed Mundi Khandwa (Appellant / Assessee) (Revenue) Pan: Aaufs0703N Assessee By Shri Gagan Tiwari, Ar Revenue By Ms. Simran Bhullar, Cit-Dr Date Of Hearing 05.10.2023 Date Of Pronouncement 30.10.2023

Section 12ASection 138Section 143(3)Section 263

182/-. The Pr. CIT after considering replied of the assesse held that the AO has totally failed to conduct proper inquiry and thorough examination of the cash book with the corresponding entries of the bank account of the assesse and accordingly the order of the AO was held to be erroneous so far as prejudicial to the interest of revenue

THE ACIT, CENTRAL-2, INDORE vs. M/S. SHAKTI PUMPS (INDIA) LTD., INDORE

ITA 1358/IND/2016[2010-11]Status: DisposedITAT Indore26 Apr 2023AY 2010-11

Bench: Ms. Madhumita Roy & Shri B.M. Biyani(Virtual Hearing) Assessment Year: 2010-11 Acit (Central)-2, Shakti Pumps (India) Ltd. Indore 226, Shastri Market, बनाम/ M.G. Road, Vs. Indore (Appellant / Revenue) (Respondent / Assessee) Pan: Aaecs 5027 L Revenue By Shri P.K. Mishra, Cit-Dr Assessee By Ms. Nisha Lahoti & Vijay Bansal, Ars Date Of Hearing 23/11/2022 / 22.02.2023 Date Of Pronouncement 26.04.2023

Section 10ASection 143(2)Section 143(3)Section 145Section 263

transfer of goods or services. 2.29 The contention of the appellant are found to be correct in as much as that the Ld. AO has passed the assessment order u/s 143(3) but has approached on an estimation basis which is arbitrary, adhoc and devoid of any basis. The Ld. AO is free to resort to making assessment