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80 results for “transfer pricing”+ Section 41clear

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Key Topics

Section 271D182Section 143(3)105Section 8087Section 269S78Section 14755Section 12A53Addition to Income42Section 153A36Deduction27

COMPUTER SCIENCES CORPORATION INDIA PRIVATE LIMITED,CHENNAI vs. ACIT, CHENNAI

ITA 1654/CHNY/2011[2007-08]Status: DisposedITAT Indore06 Oct 2023AY 2007-08

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2007-08 Computer Sciences Acit, Corporation India Private Company Circle 1(3), Limited, Chennai [Formerly Covansys (India) Private Limited], बनाम/ Unit 13, Block 2, Sdf Buildings, Vs. Madras Export Processing Zone, Tambaram, Chennai (Assessee / Appellant) (Revenue / Respondent) Pan: Aaacc1351M Assessee By Shri Neeraj Jain, Adv. Shri Abhishek Agrawal, Ca Revenue By Shri P.K. Mishra, Cit Dr Date Of Hearing 12.07.2023 Date Of Pronouncement

Section 10ASection 143(2)Section 143(3)Section 144C(5)Section 14ASection 92C

Transfer Pricing Officer (TPO). During proceeding, the TPO accepted (i) TNMM as ‘most appropriate method’, and (ii) OP/OC% as “PLI” for working of TNMM, as adopted by assessee. But he made certain modifications in the approach of assessee. He observed that the assessee-company was having 5 different units at different locations, namely (i) Bangalore Unit, (ii) Bangalore Strategic Business

Showing 1–20 of 80 · Page 1 of 4

Disallowance26
Section 80I25
Exemption18

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

Transfer Pricing officer, Ahmedabad (TPO) in the order passed u/s 92CA(3). 4.2. The appellant company has entered into transaction of sale and purchase of goods from its sister concern mainly from M/s. Manish Agrotech Limited Ltd. and it has purchased goods worth Rs. 41,67,84,935 - and sold goods worth Rs. 22,20,74,867/- to M/s Manish

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

Transfer Pricing officer, Ahmedabad (TPO) in the order passed u/s 92CA(3). 4.2. The appellant company has entered into transaction of sale and purchase of goods from its sister concern mainly from M/s. Manish Agrotech Limited Ltd. and it has purchased goods worth Rs. 41,67,84,935 - and sold goods worth Rs. 22,20,74,867/- to M/s Manish

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

Transfer Pricing officer, Ahmedabad (TPO) in the order passed u/s 92CA(3). 4.2. The appellant company has entered into transaction of sale and purchase of goods from its sister concern mainly from M/s. Manish Agrotech Limited Ltd. and it has purchased goods worth Rs. 41,67,84,935 - and sold goods worth Rs. 22,20,74,867/- to M/s Manish

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

M/S SHREE JAIRAM EDUCATION SOCIETY,BHOPAL vs. PR. CIT (CENTRAL), BHOPAL

In the result, appeal of the assessee in ITANo

ITA 90/IND/2019[-]Status: DisposedITAT Indore13 Oct 2021

Bench: Hon’Ble Rajpal Yadav & Shri Manish Boradvirtual Hearing

Section 12ASection 132Section 143(2)Section 148Section 37

transferring PAN of the assesse society from DCIT(E), Bhopal to ACIT(central) -2 Bhopal. Once the PAN is migrated then CIT(E) seize to have any jurisdiction over the assessee with regard to any of proceedings under the Act. We accordingly dismiss the additional grounds raised by the assessee. Shri Jairam Education Society ITA No.90 & 548/Ind/2019 15. Apropos

M/S SHREE JAIRAM EDUCATION SOCIETY,BHOPAL vs. ACIT CENTRAL-II, BHOPAL

In the result, appeal of the assessee in ITANo

ITA 548/IND/2019[2010-11]Status: DisposedITAT Indore13 Oct 2021AY 2010-11

Bench: Hon’Ble Rajpal Yadav & Shri Manish Boradvirtual Hearing

Section 12ASection 132Section 143(2)Section 148Section 37

transferring PAN of the assesse society from DCIT(E), Bhopal to ACIT(central) -2 Bhopal. Once the PAN is migrated then CIT(E) seize to have any jurisdiction over the assessee with regard to any of proceedings under the Act. We accordingly dismiss the additional grounds raised by the assessee. Shri Jairam Education Society ITA No.90 & 548/Ind/2019 15. Apropos

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)

41,057 Shublaxmi Commodities Rs. 3,48,70,652 Shublaxmi Traders Rs. 10,39,46,427 (Rs. 10,39,48,092/- less Rs. 1,665/-) Total Rs. 14,89,58,136 3.3 That the transactions with aforesaid brokers were made at the National Multi Commodity Exchange of India Limited (NMCE) through the authorized brokers duly substantiated by the contract notes

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)

41,057 Shublaxmi Commodities Rs. 3,48,70,652 Shublaxmi Traders Rs. 10,39,46,427 (Rs. 10,39,48,092/- less Rs. 1,665/-) Total Rs. 14,89,58,136 3.3 That the transactions with aforesaid brokers were made at the National Multi Commodity Exchange of India Limited (NMCE) through the authorized brokers duly substantiated by the contract notes

SMT. SANDHYA KHANDELWAL,INDORE vs. ITO 4(3), INDORE

In the result, all the captioned appeals filed by different

ITA 113/IND/2019[2014-15]Status: DisposedITAT Indore25 Jun 2021AY 2014-15

Bench: Hon’Ble Madhumita Royassessment Year 2014-15

Section 10(38)Section 143(3)Section 68

41,85,762/- was nothing but unexplained Cash Credit under section 68 of the Act to be taxed @ 30% under section 115BBE of the Income Tax Act, 1961 in the hands of the assessee. Radheyshyam Khandelwal & Ors ITA No.7,8,29,30,& 113/Ind/2019 6. In the first appeal, the Ld. Commissioner of Income Tax (Appeals) confirmed the order

SHRI SURESH KHANDELWAL,INDORE vs. THE ITO-4(1), INDORE

In the result, all the captioned appeals filed by different

ITA 29/IND/2019[2014-15]Status: DisposedITAT Indore25 Jun 2021AY 2014-15

Bench: Hon’Ble Madhumita Royassessment Year 2014-15

Section 10(38)Section 143(3)Section 68

41,85,762/- was nothing but unexplained Cash Credit under section 68 of the Act to be taxed @ 30% under section 115BBE of the Income Tax Act, 1961 in the hands of the assessee. Radheyshyam Khandelwal & Ors ITA No.7,8,29,30,& 113/Ind/2019 6. In the first appeal, the Ld. Commissioner of Income Tax (Appeals) confirmed the order

SMT. RUKMANI KHANDELWAL,INDORE vs. ITO-4(3), INDORE

In the result, all the captioned appeals filed by different

ITA 30/IND/2019[2014-15]Status: DisposedITAT Indore25 Jun 2021AY 2014-15

Bench: Hon’Ble Madhumita Royassessment Year 2014-15

Section 10(38)Section 143(3)Section 68

41,85,762/- was nothing but unexplained Cash Credit under section 68 of the Act to be taxed @ 30% under section 115BBE of the Income Tax Act, 1961 in the hands of the assessee. Radheyshyam Khandelwal & Ors ITA No.7,8,29,30,& 113/Ind/2019 6. In the first appeal, the Ld. Commissioner of Income Tax (Appeals) confirmed the order

MOHANLAL KHANDELWAL,INDORE vs. THE ITO-4(1), INDORE

In the result, all the captioned appeals filed by different

ITA 8/IND/2019[2014-15]Status: DisposedITAT Indore25 Jun 2021AY 2014-15

Bench: Hon’Ble Madhumita Royassessment Year 2014-15

Section 10(38)Section 143(3)Section 68

41,85,762/- was nothing but unexplained Cash Credit under section 68 of the Act to be taxed @ 30% under section 115BBE of the Income Tax Act, 1961 in the hands of the assessee. Radheyshyam Khandelwal & Ors ITA No.7,8,29,30,& 113/Ind/2019 6. In the first appeal, the Ld. Commissioner of Income Tax (Appeals) confirmed the order

RADHESHYAM KHANDELWAL,INDORE vs. ACIT4(1), INDORE

In the result, all the captioned appeals filed by different

ITA 7/IND/2019[2014-15]Status: DisposedITAT Indore25 Jun 2021AY 2014-15

Bench: Hon’Ble Madhumita Royassessment Year 2014-15

Section 10(38)Section 143(3)Section 68

41,85,762/- was nothing but unexplained Cash Credit under section 68 of the Act to be taxed @ 30% under section 115BBE of the Income Tax Act, 1961 in the hands of the assessee. Radheyshyam Khandelwal & Ors ITA No.7,8,29,30,& 113/Ind/2019 6. In the first appeal, the Ld. Commissioner of Income Tax (Appeals) confirmed the order

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)

Section 194J of the Act is not attracted in the case of "revenue sharing contract". According to Respondent No.1, in such contracts there is only sharing of revenue and, therefore, payments by revenue sharing cannot constitute "fees" under Section 194J of the Act. This submission is not accepted by the Department. We leave it there because this submission

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)

Section 194J of the Act is not attracted in the case of "revenue sharing contract". According to Respondent No.1, in such contracts there is only sharing of revenue and, therefore, payments by revenue sharing cannot constitute "fees" under Section 194J of the Act. This submission is not accepted by the Department. We leave it there because this submission

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)

Section 194J of the Act is not attracted in the case of "revenue sharing contract". According to Respondent No.1, in such contracts there is only sharing of revenue and, therefore, payments by revenue sharing cannot constitute "fees" under Section 194J of the Act. This submission is not accepted by the Department. We leave it there because this submission

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

section 144C(13) in pursuant to the directions of DRP dated 26.12.2016 passed u/s 144C(5) of the Act for Assessment Year 2012-13. 2. The assesse has under gone the liquidation process before the NCLT vide order dated 22.10.2020 the liquidator was appointed by NCLT. Page 1 of 17 Bhatia Global Trading Ltd. Page 2 of 17 3. None

SHRI RAKESH JAIN,INDORE vs. I T O IT & TP, BHOPAL

In the result, the appeal of the assessee is set aside to the file of ld

ITA 7/IND/2020[2016-17]Status: DisposedITAT Indore11 Jan 2023AY 2016-17

Bench: SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEBER, SHRI B.M. BIYANI, ACCOUNTNT MEMBER Shri Rakesh Jain, 35, Ravi Nagar, Khajrana Road, Indore

For Appellant: Shri Anil Kamal Garg, A.RFor Respondent: Shri Ashish Porwal, Sr. D.R
Section 143(3)Section 69

section 143(3) of the Income Tax Act, 1961; in short “the Act”. 2. The assessee has taken the following grounds of appeal:- I.T.A No. 07/Ind/2020 A.Y. 2016-17 Page No 2 Shri Rakesh Jain vs. ITO IT & TP “Grounds of Income-Tax appeal before the Hon'ble Income-Tax Appellate Tribunal, Indore Bench, Indore, against the Appellate Order passed

ANDRITZ HYDRO P LTD,BHOPAL vs. PR CIT-1, BHOPAL

ITA 199/IND/2020[2015-16]Status: DisposedITAT Indore29 Oct 2021AY 2015-16

Bench: Shri Manish Borad & Ms. Madhumita Royvirtual Hearing

Section 115JSection 253Section 263

price of Rs. 46 per dollar. Suppose at the end of the year 31st March, the rate of dollar has gone up to Rs. 43, the assessee's claim is that the difference of Rs. 1 (Rs. 43 -42) as on 31 st March, 1998 should be taken as loss and allowed deduction accordingly. The Special Bench of the Tribunal