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10 results for “transfer pricing”+ Section 40A(2)clear

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Key Topics

Disallowance8Section 2637Addition to Income7Section 686Section 143(3)3Section 1473Limitation/Time-bar3Condonation of Delay3Section 40

THE ADDL. CIT RANGE -1, INDORE vs. M/S PRAKASH OILS LTD., DHAR

In the result, the above captioned appeals filed by the Revenue as well as the

ITA 227/IND/2021[2015-16]Status: DisposedITAT Indore30 Jan 2023AY 2015-16

Bench: Shri C.M. Garg & Shri Bhagirath Mal Biyani

For Appellant: Shri Ajay Tulsian, CA &For Respondent: Shri P.K. Mishra, CIT, DR
Section 147

section 92BA(i). 5.1. The appellant company has entered into transactions with its sister concerns during the year under consideration but the auditors of the company, without dwelling upon the shareholding pattern of the companies, treated the ‘sister concern‘ as related party’ and reported the said transactions as transactions covered u/s 40A(2)(b) and in Form 3CEB

THE ACIT,CENTRAL-1, INDORE vs. M/S PRAKASH OILS LTD., DHAR

In the result, the above captioned appeals filed by the Revenue as well as the

2
Section 40A(3)2
Depreciation2
ITA 235/IND/2021[2011-12]Status: Disposed
ITAT Indore
30 Jan 2023
AY 2011-12

Bench: Shri C.M. Garg & Shri Bhagirath Mal Biyani

For Appellant: Shri Ajay Tulsian, CA &For Respondent: Shri P.K. Mishra, CIT, DR
Section 147

section 92BA(i). 5.1. The appellant company has entered into transactions with its sister concerns during the year under consideration but the auditors of the company, without dwelling upon the shareholding pattern of the companies, treated the ‘sister concern‘ as related party’ and reported the said transactions as transactions covered u/s 40A(2)(b) and in Form 3CEB

THE ACIT ,CENTRAL-1, INDORE vs. M/S PRAKASH OILS LTD., DHAR

In the result, the above captioned appeals filed by the Revenue as well as the

ITA 226/IND/2021[2012-2013]Status: DisposedITAT Indore30 Jan 2023AY 2012-2013

Bench: Shri C.M. Garg & Shri Bhagirath Mal Biyani

For Appellant: Shri Ajay Tulsian, CA &For Respondent: Shri P.K. Mishra, CIT, DR
Section 147

section 92BA(i). 5.1. The appellant company has entered into transactions with its sister concerns during the year under consideration but the auditors of the company, without dwelling upon the shareholding pattern of the companies, treated the ‘sister concern‘ as related party’ and reported the said transactions as transactions covered u/s 40A(2)(b) and in Form 3CEB

THE DCIT1(1), INDORE vs. SHRI RAVI ARORA, INDORE

ITA 212/IND/2020[2011-12]Status: DisposedITAT Indore31 Jul 2023AY 2011-12

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year:2011-12 Dcit-5(1), Shri Ravi Arora, Indore 1007, Khatiwala Tank, बनाम/ 236, Indraprasth Tower, 6, M.G. Road, Vs. Indore. (Revenue / Appellant) (Assessee / Respondent) Pan: Agdpa8921H Assessee By Shri Yash Kukreja, Ca & Shri Hitesh Chimnani, Adv & Ld. Ars Revenue By Shri P.K.Mishra, Cit Dr Date Of Hearing 04.05.2023 Date Of Pronouncement 31.07.2023

Section 143(2)Section 143(3)Section 40A(3)Section 68

Price Qty. Sold LTCG Share Purchase Purchase Satyam 09.01.2009 1,82,849 07.06. 2010 17,32,336 25,000 15,08,959 Computer Services Ltd Satyam 09.01.2009 1,37,137 13.07.2010 18,05,628 50,000 16,38,095 Computer Services Ltd Satyam 09.01.2009 2,18,562 27.10.2010 16,13,541 70,000 13,34,319 Computer Services Ltd Total

THE ACIT, CENTRAL-1, INDORE vs. M/S. MANISH AGRO TECH PVT. LTD., INDORE

In the result grounds of revenue for A

ITA 219/IND/2021[2015-16]Status: DisposedITAT Indore30 Jan 2023AY 2015-16

Bench: Shri Chandra Mohan Garg & Shri Bhagirath Mal Biyani

For Appellant: Shri Ruchira SinghalFor Respondent: Shri P.K Mishra, CIT (DR)

transfer pricing proceedings. Whenever a notice was received from the TPO, it was forwarded to the counsel at Ahmedabad. Cross Objection Nos.5 & 6/Ind/2020 Assessment Years: 2012-13 & 2015-16 4.8. The appellant had filed substantial documents for vindicating its transactions held with sister concern. This is also evident from the written submission filed before the TPO, copies enclosed at page

THE ACIT, CENTRAL-1, INDORE vs. M/S. MANISH AGRO TECH PVT. LTD., INDORE

In the result grounds of revenue for A

ITA 218/IND/2021[2012-13]Status: DisposedITAT Indore30 Jan 2023AY 2012-13

Bench: Shri Chandra Mohan Garg & Shri Bhagirath Mal Biyani

For Appellant: Shri Ruchira SinghalFor Respondent: Shri P.K Mishra, CIT (DR)

transfer pricing proceedings. Whenever a notice was received from the TPO, it was forwarded to the counsel at Ahmedabad. Cross Objection Nos.5 & 6/Ind/2020 Assessment Years: 2012-13 & 2015-16 4.8. The appellant had filed substantial documents for vindicating its transactions held with sister concern. This is also evident from the written submission filed before the TPO, copies enclosed at page

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

40A (3) of the income tax act. It is apparent from the audit objection filed before us at page number 30 of the paper book that the case of the assessee was selected for the scrutiny to verify only the cash deposit in the bank account of the assessee. The issue before us is whether assessing officer has made

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

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

ASSISTANT COMMISSIONER OF INCOME TAX, RATLAM vs. SHRI SURESH CHAND JAIN, MEGHNAGAR DIST. JHABUA

In the result, the appeal filed by the revenue for A

ITA 791/IND/2017[2012-13]Status: DisposedITAT Indore12 Sept 2023AY 2012-13

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani & Acit 5(1) Shri Suresh Chand Jain Indore 99, Thandla Road, Vs. Meghnagar,Jhabua (Appellant / Revenue) (Respondent/ Assessee) Pan:Aezpj 2697F Revenue By Shri P.K. Mishra, Cit-Dr Respondent By None Date Of Hearing 09.08.2023 Date Of Pronouncement 12 .09.2023

Section 40Section 68

2 of 18 ITA No.791/Ind/2017 & ITANo.431/Ind/2018 Shri Suresh Chan Jain Page 3 of 18 further noted that these vehicles have not done any transport work up to January or February 2012 and assesse has shown only for last two or three months as transport work done by these vehicles for which no payment was made even for the month

ASSISTANT COMMISSIONER OF INCOME TAX, RATLAM, RATLAM vs. SHRI SURESH CHAND JAIN, JHABUA

In the result, the appeal filed by the revenue for A

ITA 431/IND/2018[14-15]Status: DisposedITAT Indore12 Sept 2023

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani & Acit 5(1) Shri Suresh Chand Jain Indore 99, Thandla Road, Vs. Meghnagar,Jhabua (Appellant / Revenue) (Respondent/ Assessee) Pan:Aezpj 2697F Revenue By Shri P.K. Mishra, Cit-Dr Respondent By None Date Of Hearing 09.08.2023 Date Of Pronouncement 12 .09.2023

Section 40Section 68

2 of 18 ITA No.791/Ind/2017 & ITANo.431/Ind/2018 Shri Suresh Chan Jain Page 3 of 18 further noted that these vehicles have not done any transport work up to January or February 2012 and assesse has shown only for last two or three months as transport work done by these vehicles for which no payment was made even for the month