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8 results for “transfer pricing”+ Section 234clear

Sorted by relevance

Delhi407Mumbai314Karnataka290Surat132Bangalore125Ahmedabad86Jaipur69Kolkata51Chennai48Chandigarh33Pune29Hyderabad21Calcutta19Cuttack12Lucknow9Nagpur9Rajkot9Visakhapatnam8Indore8SC7Cochin7Raipur6Telangana4Varanasi4Rajasthan3A.K. SIKRI N.V. RAMANA1Andhra Pradesh1Ranchi1Allahabad1T.S. THAKUR ROHINTON FALI NARIMAN1Jodhpur1

Key Topics

Section 144C(13)9Section 143(3)7Section 54F6Addition to Income5Transfer Pricing4Disallowance4Section 144C(8)3Double Taxation/DTAA3Exemption

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

3
Section 144C(5)2
Section 14A2
Section 43(1)2

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

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

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. BHATIA GLOBAL TRADING LTD.,INDORE vs. THE DCIT 1(1), INDORE

In the result, appeal of assessee is partly allowed

ITA 247/IND/2017[2012-13]Status: DisposedITAT Indore26 Jul 2023AY 2012-13

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanibhatia Global Trading Ltd. Dcit 1(1) Through Official Liquidator Indore Old Cia Building, 1St Floor Vs. Opp. G.P.O. Residency Area, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaacb6751 C Assessee By None Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 10.05.2023 Date Of Pronouncement 26 .07.2023

Section 143(3)Section 144C(13)Section 144C(5)Section 14A

transfer pricing regulations 5. The TPO rejected the TP Study analysis of the assesse and carried out his own search for selecting comparable for determination of arm’s length price. The TPO selected three comparable companies for determination of arm’s length price against which the assessee has raised objection before the DRP which are reproduced

ACIT CENTRAL-2 INDORE, INDORE vs. SHRI .GAURAV TEKRIWAL, INDORE

In the result, this appeal of Revenue is dismissed

ITA 62/IND/2021[2015-16]Status: DisposedITAT Indore21 Nov 2022AY 2015-16

Bench: Ms. Madhumita Roy & Shri B.M. Biyani(Conducted Through Virtual Court) Assessment Year: 2015-16 Acit, Central -2 Shri Gaurav Tekriwal Indore बनाम/ 204, Princess Valley, South Tukoganj, Indore Vs. (Appellant / Revenue) (Respondent / Revenue) Pan: Acppt 1628 Q Assessee By Shri Anil Kamal Garg, Arpit Gaur, Ars Revenue By Shri P.K. Mitra, Cit-Dr Date Of Hearing 21.09.2022 Date Of Pronouncement 21.11.2022

Section 143(2)Section 143(3)Section 2Section 54FSection 55(2)(a)Section 57

234 of the Paper-Book which gives complete date-wise, party-wise details of expenditure of Rs. 53,13,484/- incurred on completing the structure. On perusal of this ledger account, we observe that the assessee has made payments on account of material, labour, etc. The payments have been made to established business concerns, like M/s Gandhi Hardware Stores

THE ACIT, CIRCLE 2(1), INDORE vs. DR. SHRI RAJEEV CHAUDHARY, INDORE

In the result, the appeal of the revenue is allowed and cross objection of the assessee is partly allowed

ITA 293/IND/2012[2008-09]Status: DisposedITAT Indore10 Jan 2019AY 2008-09

Bench: Hon'Ble I Kul Bharat & Hon'Ble Manish Boradassessment Year 2008-09 Pan : Abkpc5729K Assistant Commissioner Of V/S Dr.Rajeev Choudhary Income Tax, 1, Shiv Vilas Palace Circle-2(1), Indore Indore

Section 147Section 14A

price, without anything more, is consistent with the realization of capital investment and surplus received by the assessee will not be trading or business profit. 02. That the learned CIT(A) has confirmed the disallowance made by the learned AO of Rs. 2,15,542/- by invoking the provision of section 14A to be read with Rule