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10 results for “transfer pricing”+ Section 801clear

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Key Topics

Section 6811Section 143(3)9Section 10(38)9Addition to Income8Section 1476Section 143(2)5Long Term Capital Gains5Section 14A4Penny Stock

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)

section 65A and 65B of the Indian Evidence Act 1872 providing for admissibility of electronic records as evidence have not been followed. The appellant has also placed reliance on certain decisions wherein, on identical facts, similar addition made have been deleted. 4.2.2 After considering the observation made in the assessment order and also taking into consideration the written submissions

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 2023
4
Disallowance4
Section 1483
Exemption3
AY 2015-16

Bench: Shri Chandra Mohan Garg & Shri Bhagirath Mal Biyani

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

section 65A and 65B of the Indian Evidence Act 1872 providing for admissibility of electronic records as evidence have not been followed. The appellant has also placed reliance on certain decisions wherein, on identical facts, similar addition made have been deleted. 4.2.2 After considering the observation made in the assessment order and also taking into consideration the written submissions

RUPESH VYAS,INDORE vs. THE ACIT3(1), INDORE, INDORE

In the result, this appeal of assessee is dismissed

ITA 50/IND/2020[150-16]Status: DisposedITAT Indore06 Dec 2022

Bench: Shri T.R. Senthil Kumar & Shri B.M. Biyani

Section 10(38)Section 143(3)Section 68Section 69C

transferred to the beneficiary at a very nominal price mostly off-line through preferential allotment or off-line sale to save SIT. The beneficiary (an Individual) holds the share for one year, the statutory period after which LTCG is exempt under section 10(38) of the Income Tax Act, 1961. In the meantime the operators rig the price

RUPESH VYAS,INDORE vs. THE ACIT3(1), INDORE, INDORE

In the result, this appeal of assessee is dismissed

ITA 909/IND/2018[2014-15]Status: DisposedITAT Indore07 Dec 2022AY 2014-15

Bench: Ms. Suchitra Kamble & Shri B.M. Biyani

Section 10(38)Section 143(3)Section 68Section 69C

transfer of long term 'capital asset' was not includible in total income of the assessee in view of section 10(38) of the Act. 2.2. That the learned Commissioner of Income Tax (Appeals) has failed to appreciate the evidence tendered by the appellant to support the claim of sale of shares and hence, findings mechanically recorded on borrowed inference

SHRI ABHISHEK GUPTA,INDORE vs. ITO-5(5), INDORE

In the result, this appeal of assessee is dismissed

ITA 74/IND/2019[2014-15]Status: DisposedITAT Indore17 Aug 2022AY 2014-15

Bench: Ms. Suchitra Kamble & Shri B.M. Biyani

Section 10(38)Section 143(2)Section 143(3)Section 68

Transfer in Single Scrip of M/s Turbo Tech Engineers Ltd. 6. That on the fact and in the circumstances of the case, the learned CIT (A) has erred in confirming the action of AO regarding addition of the Notional Commission calculated on such Share Transaction without any evidence to whom paid. 7. That the appellant reserves its right

SHIVKRIPA DEVCON P LTD,INDORE vs. ITO 5(1), INDORE

ITA 1/IND/2022[2012-13]Status: DisposedITAT Indore28 Aug 2023AY 2012-13

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2012-13

Section 143(2)Section 143(3)Section 147Section 148

801 (SC) (b) Hersh Win Chadha Vs. DCIT, ITA No. 3088 to 3098 & 3107/Del/2005 (c) Sumati Dayal Vs. CIT 1995 AIR 2009 (SC) (d) McDowell & Co. Ltd. Vs. CTO 1986 AIR 649 (SC) (e) Sanjay Bimal Chand Jain Vs. PCIT, Nagpur (Bombay HC) (f) M.K. Rajeshwari Vs. ITO, Ward-3, Raichur (ITAT, Bangalore) Then, the Ld. AR carried

PARMANAND SACHDEV,INDORE vs. ITO 5(5), INDORE

In the result, this appeal of assessee is dismissed

ITA 609/IND/2019[2014-15]Status: DisposedITAT Indore01 Dec 2022AY 2014-15

Bench: Ms. Suchitra Kamble & Shri B.M. Biyani

Section 10(38)Section 143(2)Section 143(3)Section 250Section 68

801 (SC) (b) Shammin Varmani, ITA No. 4906/Mum/2011 (c) Ziauddin A. Siddique ITA No. 4699 and 4700/Mum/2011 12. During first appellate proceeding, the assessee submitted a detailed reply to Ld. CIT(A) reiterating almost same submissions as made before Ld. AO but with the support of some more judicial precedents. However, the assessee did not find any favour from

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

DECENT INDUSTRIES P. LTD.,BHOPAL vs. ITO-1(2), BHOPAL

Appeal is partly allowed

ITA 356/IND/2023[2012-13]Status: DisposedITAT Indore20 Aug 2024AY 2012-13

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani(Virtual Hearing) Assessment Year: 2012-13 M/S Decent Industries Ito-1(2), Private Ltd, Bhopal 5Th Floor, Corporate Park, बनाम/ Db City Area Hills, Vs. Opp. M.P. Nagar Zone I, Bhopal (Assessee/Appellant) (Revenue/Respondent) Pan: Aaeca6271G Assessee By Ms. Shilpa Gupta & Shri N.K. Gupta Revenue By Shri V.K. Singh, Cit-Dr Date Of Hearing 04.06.2024 Date Of Pronouncement 20.08.2024

Section 133ASection 143(2)Section 147Section 148Section 14ASection 68

price of the shares is decided on the mutual understanding of the parties concerned. Page 15 of 44 M/s Decent Industries Pvt. Ltd ITA No. 356/Ind/2023 – AY 2012-13 53. Once the genuineness, creditworthiness and identity are established, the revenue should not justifiably claim to put itself in the armchair of a businessman or in the position of the Board

DEPUTY COMMISSIONER OF INCOME TAX - 3(1), INDORE vs. SHRI RAJEEV AJMERA, INDORE

In the result, the appeal of Revenue is partly allowed for statistical purposes

ITA 51/IND/2018[2010-11]Status: DisposedITAT Indore31 Aug 2022AY 2010-11

Bench: Ms.Suchitra Kamble & Shrib.M. Biyani(Conducted Through Virtual Court) Assessment Year: 2010-11 Dcit-3(1) Shri Rajeev Ajmera, Indore बनाम/ Indore Vs. (Appellant / Assessee) (Respondent / Revenue) Pan: Abgpa4930L Co No.23/Ind/2018 (Arising Out Of Ita No.51/Ind/2018) Assessment Year: 2010-11 Shri Rajeev Ajmera, Dcit-3(1) Indore Indore बनाम/ Vs. (Appellant / Assessee) (Respondent / Revenue) Pan: Abgpa4930L Assessee By Shri Mahendra Mittal, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 23.08.2022 Date Of Pronouncement 31.08.2022 आदेश/ O R D E R

Section 143(2)Section 143(3)Section 14ASection 44A

801, disallowed the deduction. 8. During first-appellate proceeding, the assessee made a detailed submission to Ld. CIT(A). The assessee also invoked Rule 46A and submitted several additional-evidences, the details of which are mentioned by Ld. CIT(A) in the form of a long-list on Page No. 32 to 34 of his order. Although