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67 results for “transfer pricing”+ Section 2(24)(x)clear

Sorted by relevance

Delhi1,339Mumbai980Bangalore413Karnataka313Ahmedabad244Kolkata189Hyderabad175Jaipur166Chennai153Chandigarh112Pune108Indore67Calcutta53Cochin52Surat40Raipur27Telangana27Rajkot21Guwahati21Nagpur20Lucknow19SC19Cuttack15Jodhpur14Amritsar13Visakhapatnam12Agra10Ranchi8Allahabad5Rajasthan4Orissa3Panaji2Dehradun2DIPAK MISRA V. GOPALA GOWDA1T.S. THAKUR ROHINTON FALI NARIMAN1A.K. SIKRI ROHINTON FALI NARIMAN1A.K. SIKRI N.V. RAMANA1

Key Topics

Section 143(3)63Section 153A49Addition to Income48Section 6824Section 26319Disallowance13Section 143(2)11Section 56(2)(x)11Section 13210

ACIT 5 (1), BHOPAL vs. M/S VINDHYA SOLVENT PVT. LTD., BHOPAL

In the result, Revenue’s appeal is dismissed

ITA 281/IND/2018[14-15]Status: DisposedITAT Indore18 Oct 2022

Bench: Ms. Madhumita Roy& Shri Bhagirath Mal Biyani

For Appellant: RespondentbyFor Respondent: Shri Sumit Nema, Sr
Section 142(1)Section 143(2)Section 143(3)Section 56(2)(viib)Section 68

price and consequently the share premium, it cannot be said that share premium solely, depends on the future realizable value of profits. In any case, this observation is legally not relevant in view of express provision of law. 8.33 In view of the totality of facts and legal position, as the law i.e. section 56(2)(viib) and Rule 11UA

Showing 1–20 of 67 · Page 1 of 4

Section 80I10
Survey u/s 133A8
Penalty7

D.K. CONSTRUCTIONS,BHOPAL vs. CENTRAL CIRCLE - 1, BHOPAL, BHOPAL

Appeal is dismissed

ITA 316/IND/2024[2018-19]Status: DisposedITAT Indore28 Aug 2024AY 2018-19

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2018-19 D.K.Constructions, Pcit (Central), Dk Cottage, Bhopal 24, Carat E8, बनाम/ Near Gujrati Colony,, Vs. Bawadiya Kalan, Bhopal (Assessee/Appellant) (Revenue/Respondent) Pan: Aaafd7121P Assessee By Shri S.S. Deshpande, Ca Revenue By Shri Ram Kumar Yadav, Cit Dr Date Of Hearing 28.08.2024 Date Of Pronouncement 30.08.2024

Section 143(3)Section 263Section 44ASection 56(2)(vii)Section 56(2)(x)

24, Carat E8, बनाम/ Near Gujrati Colony,, Vs. Bawadiya Kalan, Bhopal (Assessee/Appellant) (Revenue/Respondent) PAN: AAAFD7121P Assessee by Shri S.S. Deshpande, CA Revenue by Shri Ram Kumar Yadav, CIT DR Date of Hearing 28.08.2024 Date of Pronouncement 30.08.2024 आदेश / O R D E R Per B.M. Biyani, A.M.: Feeling aggrieved by revision-order dated 26.03.2024 passed by learned Pr. Commissioner

THE DCIT-1(1), INDORE vs. M/S. AGRAWAL COAL CORPORATION P. LTD., INDORE

ITA 607/IND/2015[2009-10]Status: DisposedITAT Indore08 Mar 2017AY 2009-10

Bench: Shri D.T. Garasia & Shri O.P. Meena

x) erred in giving the aforesaid relief while ignoring that the TPO did not take bank guarantee rates as CUP, but used US Bond data rate for benchmarking. (xi) erred in deleting the addition of Rs. 73,15,000/- made on account of unexplained cash credit received from those parties who were already hit by section 68 in the immediately

THE DCIT1(1), INDORE vs. M/S. AGRAWAL COAL CORPORATION P LTD., INDORE

ITA 622/IND/2015[2010-11]Status: DisposedITAT Indore08 Mar 2017AY 2010-11

Bench: Shri D.T. Garasia & Shri O.P. Meena

x) erred in giving the aforesaid relief while ignoring that the TPO did not take bank guarantee rates as CUP, but used US Bond data rate for benchmarking. (xi) erred in deleting the addition of Rs. 73,15,000/- made on account of unexplained cash credit received from those parties who were already hit by section 68 in the immediately

M/S. AGRAWAL COAL CORPORATION P. LTD.,INDORE vs. THE DCIT -CIRCLE 1(1), INDORE

ITA 602/IND/2015[2010-11]Status: DisposedITAT Indore08 Mar 2017AY 2010-11

Bench: Shri D.T. Garasia & Shri O.P. Meena

x) erred in giving the aforesaid relief while ignoring that the TPO did not take bank guarantee rates as CUP, but used US Bond data rate for benchmarking. (xi) erred in deleting the addition of Rs. 73,15,000/- made on account of unexplained cash credit received from those parties who were already hit by section 68 in the immediately

M/S. AGRAWAL COAL CORPORATION P. LTD.,INDORE vs. THE DCIT RANGE 1(1), INDORE

ITA 601/IND/2015[2009-10]Status: DisposedITAT Indore08 Mar 2017AY 2009-10

Bench: Shri D.T. Garasia & Shri O.P. Meena

x) erred in giving the aforesaid relief while ignoring that the TPO did not take bank guarantee rates as CUP, but used US Bond data rate for benchmarking. (xi) erred in deleting the addition of Rs. 73,15,000/- made on account of unexplained cash credit received from those parties who were already hit by section 68 in the immediately

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

M/S. BIRLA CORPORATION LTD., UNIT SATNA CEMENT WORKS,SATNA vs. ITO (IT & TP), BHOPAL

In the result, Assessee’s appeals

ITA 33/IND/2020[2010-11]Status: HeardITAT Indore28 Jan 2022AY 2010-11

Bench: Shri Mahavir Prasad & Shri Manish Boradvirtual Hearing

Section 143(3)Section 5(2)(b)

X INTELLPOWER 5 MMD Asia Pacific Ltd. Purchase of complete coal crusher 6 Shanyang Heavy Machinery Vertical Roller Mill for Coal Grinding Co. Ltd. Work 7 RHI AG Purchase of Basic Brick (Ankral R2CD and S2CB) 10 Birla Corporation Ltd. ITA No.33 & 34/Ind/2020 8 RHI AG Purchase of Basic Brick (Ankral R2CB and S2CB) 10. Ld. Assessing Officer

M/S. BIRLA CORPORATION LTD., UNIT SATNA CEMENT WORKS,SATNA vs. ITO (IT & TP), BHOPAL

In the result, Assessee’s appeals

ITA 34/IND/2020[2011-12]Status: DisposedITAT Indore28 Jan 2022AY 2011-12

Bench: Shri Mahavir Prasad & Shri Manish Boradvirtual Hearing

Section 143(3)Section 5(2)(b)

X INTELLPOWER 5 MMD Asia Pacific Ltd. Purchase of complete coal crusher 6 Shanyang Heavy Machinery Vertical Roller Mill for Coal Grinding Co. Ltd. Work 7 RHI AG Purchase of Basic Brick (Ankral R2CD and S2CB) 10 Birla Corporation Ltd. ITA No.33 & 34/Ind/2020 8 RHI AG Purchase of Basic Brick (Ankral R2CB and S2CB) 10. Ld. Assessing Officer

M/S. COMPUTER SCIENCE CORPORATION INDIA PVT. LTD.,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX-CIRCLE 2(1) , INDORE

In the result, all the three appeals are partly allowed for statistical purpose and the Stay Application is also disposed of

ITA 319/IND/2018[2013-14]Status: DisposedITAT Indore10 Apr 2023AY 2013-14

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

For Appellant: Shri Vishal Kalra, AdvocateFor Respondent: Shri P.K. Mishra, CIT DR
Section 143(3)Section 144C(13)Section 144C(8)

Transfer Pricing Officer has followed the well searched formula and the data that simple year should have been taken into account. The Ld. DR submitted that the TPO has taken cognisance of the depreciation adjustment and relied upon the order of the TPO and the Assessing Officer. 11. We have heard both the parties and perused all the relevant material

M/S. COMPUTER SCIENCE CORPORATION INDIA PVT. LTD.,CHENNAI vs. THE ACIT-CIRCLE 2(1), INDORE

In the result, all the three appeals are partly allowed for statistical purpose and the Stay Application is also disposed of

ITA 292/IND/2017[2012-13]Status: DisposedITAT Indore10 Apr 2023AY 2012-13

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

For Appellant: Shri Vishal Kalra, AdvocateFor Respondent: Shri P.K. Mishra, CIT DR
Section 143(3)Section 144C(13)Section 144C(8)

Transfer Pricing Officer has followed the well searched formula and the data that simple year should have been taken into account. The Ld. DR submitted that the TPO has taken cognisance of the depreciation adjustment and relied upon the order of the TPO and the Assessing Officer. 11. We have heard both the parties and perused all the relevant material

M/S. COMPUTER SCIENCES CORPORATION INDIA PRIVATE LIMITED,INDORE vs. THE ASST. COMMISSIONER OF INCOME TAX-2(1), INDORE

In the result, all the three appeals are partly allowed for statistical purpose and the Stay Application is also disposed of

ITA 179/IND/2016[2011-12]Status: DisposedITAT Indore10 Apr 2023AY 2011-12

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

For Appellant: Shri Vishal Kalra, AdvocateFor Respondent: Shri P.K. Mishra, CIT DR
Section 143(3)Section 144C(13)Section 144C(8)

Transfer Pricing Officer has followed the well searched formula and the data that simple year should have been taken into account. The Ld. DR submitted that the TPO has taken cognisance of the depreciation adjustment and relied upon the order of the TPO and the Assessing Officer. 11. We have heard both the parties and perused all the relevant material

ALI ASGAR,RATLAM vs. CIT APPEAL, NFAC

In the result the “Impugned order” is set aside as and by

ITA 375/IND/2025[2019-2020]Status: DisposedITAT Indore17 Apr 2026AY 2019-2020

Bench: Shri B.M. Biyani & Shri Paresh M Joshiali Asgar, Cit(A) बनाम/ 221/1, Badri Colony Near Vs. Narsingh Vatika, Silawato Ka Waas, Ratlam (Pan:Bhspa5967N) (Appellant) (Respondent) Assessee By Shri Mohd. Kaid Kangsiwala, Ar Revenue By Shri Ashish Porwal, Sr.Dr Date Of Hearing 13.04.2026 Date Of Pronouncement 17.04.2026 आदेश/ O R D E R

Section 147Section 246ASection 250Section 253Section 56(2)(x)

24,06,685/-. The Income as per the return of income filed was at Rs.3,19,200/-. Addition as computed u/s 56(2)(x) was as at Rs.20,87,485/-. The aforesaid assessment order bears number:- ITBA/AST/S/147/2023-24/1061255750(1) and that the same is dated 21.02.2024 which is hereinafter referred to as the “Impugned Assessment Order.” 2.2 That the Assessee being

M/S. BHANDARI HOSPITAL AND RESEARCH CENTRE,INDORE vs. THE PR. CIT-1, INDORE

ITA 355/IND/2017[2012-13]Status: DisposedITAT Indore20 Mar 2020AY 2012-13

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2012-13 M/S Bhandari Hospital & Pr. Cit-(I) Research Centre, Gf-21 & Indore बनाम/ 22, Opp. Meghdoot Garden, Vs. Vijay Nagar, Indore (Appellant) (Revenue ) P.A. No.Aadfb8151A

Section 131(1)(d)Section 143(3)Section 144ASection 263Section 35A

transferred to another AO u/s 127 who then issued notice u/s 142(1) on 29/7/2014. (copy of this notice is on pages 108-109 of the paper book). This was a comprehensive notice requiring compliance of various issues. viii. Reply was filed by the assessee on 12.8.2014 (placed on page 110- 116 of the apper book) with all relevant information

M/S. S.R. FERRO ALLOYS,JHABUA vs. THE PCIT, BHOPAL

In the result, the appeal of assessee is allowed

ITA 148/IND/2021[2015-16]Status: DisposedITAT Indore09 Nov 2023AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanis.R. Ferro Alloys Pr. Cit, Central 9, Siddheswar Colony Bhopal Vs. Jhabua (Appellant / Assessee) (Revenue) Pan: Abhfs7377Q Appellant By Shri Sumit Nema, Sr. Adv. & Gagan Tiwari, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 12.10.2023 Date Of Pronouncement 09.11.2023

Section 263

price. A method of accounting adopted by the trader consistently and regularly cannot be discarded by departmental authorities on the view that he should have adopted a different method of keeping accounts or of valuation. The method of accounting regularly employed may be discarded only, if, in the opinion of taxing authorities, income of the trade cannot be property Page

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

THE DCIT-2(1), INDORE vs. M/S. CENTURY 21 MALL (P) LTD., INDORE

In the result, all appeals of the Revenue are dismissed, while all appeals of the assessee are allowed

ITA 255/IND/2017[2012-13]Status: DisposedITAT Indore23 Feb 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 143(3)Section 145(3)Section 153ASection 68

X + IN THE INCOME TAX APPELLATE TRIBUNAL “INDORE BENCH”, INDORE ] ] BEFORE SMT. MADHUMITA ROY, JUDICIAL MEMBER, AND SHRI BHAGIRATH MAL BIYANI, ACCOUNTANT MEMBER IT(SS)A No.166, 167 and 168 /Ind/2016 Asstt.Year : 2008-2009, 2009-2010 and 2010-11 AND Asstt.Year 2011-12 Century 21 Malls P.Ltd. Vs. ACIT, Ward-2(1) 731-732, Usha Nagar Indore. Extension Above Axis

THE DCIT, 2(1), INDORE vs. M/S. CENTURE 21 MALL PVT. LTD., INDORE

In the result, all appeals of the Revenue are dismissed, while all appeals of the assessee are allowed

ITA 952/IND/2016[2011-12]Status: DisposedITAT Indore23 Feb 2023AY 2011-12

Bench: Smt. Madhumita Roy & Shri Bhagirath Mal Biyani

For Appellant: Shri S. S. Deshpande, CAFor Respondent: Shri P.K. Mishra, CIT-DR
Section 132Section 143(3)Section 145(3)Section 153ASection 68

X + IN THE INCOME TAX APPELLATE TRIBUNAL “INDORE BENCH”, INDORE ] ] BEFORE SMT. MADHUMITA ROY, JUDICIAL MEMBER, AND SHRI BHAGIRATH MAL BIYANI, ACCOUNTANT MEMBER IT(SS)A No.166, 167 and 168 /Ind/2016 Asstt.Year : 2008-2009, 2009-2010 and 2010-11 AND Asstt.Year 2011-12 Century 21 Malls P.Ltd. Vs. ACIT, Ward-2(1) 731-732, Usha Nagar Indore. Extension Above Axis

M/S CENTURY 21 MALLS P. LTD.,INDORE vs. THE ACIT 2(1), INDORE

In the result, all appeals of the Revenue are dismissed, while all appeals of the assessee are allowed

ITA 949/IND/2016[2011-12]Status: DisposedITAT Indore23 Feb 2023AY 2011-12

Bench: Smt. Madhumita Roy & Shri Bhagirath Mal Biyani

For Appellant: Shri S. S. Deshpande, CAFor Respondent: Shri P.K. Mishra, CIT-DR
Section 132Section 143(3)Section 145(3)Section 153ASection 68

X + IN THE INCOME TAX APPELLATE TRIBUNAL “INDORE BENCH”, INDORE ] ] BEFORE SMT. MADHUMITA ROY, JUDICIAL MEMBER, AND SHRI BHAGIRATH MAL BIYANI, ACCOUNTANT MEMBER IT(SS)A No.166, 167 and 168 /Ind/2016 Asstt.Year : 2008-2009, 2009-2010 and 2010-11 AND Asstt.Year 2011-12 Century 21 Malls P.Ltd. Vs. ACIT, Ward-2(1) 731-732, Usha Nagar Indore. Extension Above Axis

CHIRAYU CHARITABLE FOUNDATION,BHOPAL vs. PCIT (CENTRAL), BHOPAL

In the result appeal of the assessee stands allowed

ITA 179/IND/2019[-]Status: DisposedITAT Indore09 Feb 2021

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Boradchirayu Charitable Pcit (Central), Foundation,Bhopal Indore Bhopal Highway, Bhaisakhedi, Vs. Bhopal (Appellant) (Revenue ) Pan No.Aaaac3656P Revenue By Shri S.S. Mantri, Cit Appellant By S/Shri Sumit Nema, Sr. Advocate, Gagan Tiwari & Piyush Parashar, Advs Date Of Hearing 05.01.2021 Date Of Pronouncement .02.2021 O R D E R Per Manish Borad, Am.

Section 12ASection 132

X. To achieve the objects, the society shall construct buildings, hospitals, clinics diagnostic centres, research centres, colleges etc. and shall raise all other necessary infrastructure, equipment, machines, tools and raise fitting and to do all necessary and incidental there for the beneficiaries. The object of the society shall not include objects involving the carrying on of activity for profit within