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

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Key Topics

Section 2637Disallowance6Addition to Income5Section 143(3)3Section 1473Limitation/Time-bar3Condonation of Delay3Section 40A(3)2Section 68

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
ITA 226/IND/2021[2012-2013]Status: Disposed
ITAT Indore
30 Jan 2023
AY 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 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 235/IND/2021[2011-12]Status: DisposedITAT Indore30 Jan 2023AY 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 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 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

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

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

b) reported in Audit Report & ITR ii. High interest expenditure against new capital 5.1 Thereafter on perusal of the record the Pr. CIT noted that the assesse has taken interest bearing loans of Rs.9.90 crores and unsecured loans of Rs.6.76 crores and debited the interest expenditure in the profit and loss account of Rs.1.10 crores. Simultaneously the assesse has given

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

b) and (c) of section 138 of the Negotiable Instruments Act, 1881 and any other laws, which prescribe period(s) of limitation for instituting proceedings, outer limits (within which the court or tribunal can condone delay) and termination of proceedings.” Page 5 of 27 ITANo.229/Ind/2023 M/s Rana & Joshi Buildtech Pvt. Ltd. 4.1 Thus, the period of limitation has been extended