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10 results for “transfer pricing”+ Section 108clear

Sorted by relevance

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Key Topics

Addition to Income10Disallowance6Section 115J4Section 143(1)4Section 374Rectification u/s 1544Section 56(2)(X)3Section 143(3)3Transfer Pricing

D.C.I.T,CIRCLE-9(1), KOLKATA vs. M/S APOLLO GLENEAGLES HOSPITAL, KOLKATA

In the result, appeal of the Revenue for AY 2012-13 is dismissed

ITA 1501/KOL/2019[2012-13]Status: DisposedITAT Kolkata27 Apr 2023AY 2012-13

Bench: Shri Sanjay Garg, Hon’Ble & Shri Girish Agrawal, Hon’Ble

For Appellant: Ms. Vandana Bhandari, FCA and Shri SaibalFor Respondent: Shri G. Hukuga Sema, CIT, D/R
Section 143(3)Section 14A

Transfer Pricing Officer at "nil".' This is a slender yet crucial distinction that restricts the authority of the TPO. Whilst the report of the TPO in this case ultimately noted that the ALP was 'nil', since a comparable entity would pay 'nil' amount for these services, this Court noted that remarks concerning, and the final decision relating to, benefit arising

D.C.I.T,CIRCLE-9(1), KOLKATA vs. M/S APOLLO GLENEAGLES HOSPITAL, KOLKATA

In the result, appeal of the Revenue for AY 2012-13 is dismissed

3
Section 92C2
Section 14A2
ITA 1639/KOL/2019[2013-14]Status: DisposedITAT Kolkata27 Apr 2023AY 2013-14

Bench: Shri Sanjay Garg, Hon’Ble & Shri Girish Agrawal, Hon’Ble

For Appellant: Ms. Vandana Bhandari, FCA and Shri SaibalFor Respondent: Shri G. Hukuga Sema, CIT, D/R
Section 143(3)Section 14A

Transfer Pricing Officer at "nil".' This is a slender yet crucial distinction that restricts the authority of the TPO. Whilst the report of the TPO in this case ultimately noted that the ALP was 'nil', since a comparable entity would pay 'nil' amount for these services, this Court noted that remarks concerning, and the final decision relating to, benefit arising

M/S. PHILIPS INDIA LIMITED,KOLKATA vs. D.C.I.T., CIRCLE - 11(1), KOLKATA

In the result, the appeal of the assessee is allowed

ITA 1960/KOL/2024[2020-2021]Status: DisposedITAT Kolkata11 Mar 2025AY 2020-2021

Bench: Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am M/S Philips India Limited Dcit, Circle 11(1) 3Rd Floor, Tower-A, Dlf Park, Aaykar Bhavan, P-7, 08 Block Af, Major Arterial Chowringhee Square, Road, New Town (Rajarhat), Vs. Kolkata-700069, Kolkata-700156, West Bengal West Bengal (Appellant) (Respondent) Pan No. Aabcp9487A Assessee By : Shri Ketan Ved, Ar Revenue By : Shri A. Kundu, Cit Dr Date Of Hearing: 07.03.2025 Date Of Pronouncement : 11.03.2025

For Appellant: Shri Ketan Ved, ARFor Respondent: Shri A. Kundu, CIT DR
Section 92Section 92C

108,79,48,589/- on account of Intra Group Services (‘IGS’) received by the assessee. M/s Philips India Limited; A.Y. 2020-21 012. We note that this is a recurring issue in the case of the assessee which has been decided by the co-ordinate Bench in favour of the assessee in ITA No. 226/KOL/2021, vide order dated

SMT. KAJARI BANERJEE,KOLKATA vs. ITO WARD-29(1), KOLKTAT

In the result, the appeal of the assessee is allowed

ITA 130/KOL/2025[2018-19]Status: DisposedITAT Kolkata19 May 2025AY 2018-19
Section 143(3)Section 50(2)(X)Section 56Section 56(2)(X)

108\ndays. Considering the reasons to be bonafide and genuine, we are\ninclined to condone the delay and admit the appeal for adjudication.\n03. The only issue raised in the various grounds of appeal is against the\napplicability of the provisions of Section 56(2)(X) of the Act by the Id.\nAO which was upheld

SEEMA SUREKA,KOLKATA vs. DCIT, CENTRAL CIRCLE - 3(3), KOLKATA

Appeal of the assessee is partly allowed

ITA 2682/KOL/2024[2015-16]Status: DisposedITAT Kolkata04 Nov 2025AY 2015-16
Section 250Section 56(2)Section 56(2)(vii)

transfer under clause (via) or clause (vic) or clause (vich) or clause (vid) or clause (vii) of\nsection 47.\n\nExplanation.—For the purposes of this clause, “fair market value” of a property, being shares of a\ncompany not being a company in which the public are substantially interested, shall have the\nmeaning assigned to it in the Explanation

NARAYAN SUPPLIERS PVT. LTD.,KOLKATA vs. I.T.O., WARD - 6(3), KOLKATA, KOLKATA

In the result, appeal of the assessee is dismissed

ITA 1077/KOL/2024[2011-2012]Status: DisposedITAT Kolkata08 Sept 2025AY 2011-2012
Section 10(38)

transferred and with whom the transaction had taken place. The\nA.O. did not verify the correctness of information received by him but\nmerely accepted the truth of the vague information in a mechanical\nmanner. The A.O. had not even recorded his satisfaction about the\ncorrectness or otherwise of the information for issuing a notice u/s\n148. What had been recorded

DCIT, CIRCLE-8(1), KOLKATA, KOLKATA vs. ITC LIMITED, KOLKATA

In the result appeals of the assessee are partly allowed for statistical purposes and the appeals of the revenue are dismissed

ITA 1222/KOL/2017[2010-11]Status: DisposedITAT Kolkata10 May 2024AY 2010-11

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 115JSection 143(1)Section 37

price as on the date of grant of such stock option. During the year, the assessee has determined Rs. 314,23,65,720/- as employee compensation cost accruing for the year based on the vesting period of the ESOPs which was duly disclosed in the Annual Account for the said year. The assessee claims to be entitled to the deduction

ITC LIMITED,KOLKATA vs. ACIT, RANGE-8, KOLKATA, KOLKATA

In the result appeals of the assessee are partly allowed for statistical purposes and the appeals of the revenue are dismissed

ITA 1166/KOL/2017[2011-12]Status: DisposedITAT Kolkata10 May 2024AY 2011-12

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 115JSection 143(1)Section 37

price as on the date of grant of such stock option. During the year, the assessee has determined Rs. 314,23,65,720/- as employee compensation cost accruing for the year based on the vesting period of the ESOPs which was duly disclosed in the Annual Account for the said year. The assessee claims to be entitled to the deduction

ITC LIMITED,KOLKATA vs. ACIT, RANGE-8, KOLKATA, KOLKATA

In the result appeals of the assessee are partly allowed for statistical purposes and the appeals of the revenue are dismissed

ITA 1068/KOL/2017[2010-11]Status: DisposedITAT Kolkata10 May 2024AY 2010-11

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 115JSection 143(1)Section 37

price as on the date of grant of such stock option. During the year, the assessee has determined Rs. 314,23,65,720/- as employee compensation cost accruing for the year based on the vesting period of the ESOPs which was duly disclosed in the Annual Account for the said year. The assessee claims to be entitled to the deduction

DCIT, CIRCLE-8(1), KOLKATA, KOLKATA vs. ITC LIMITED, KOLKATA

In the result appeals of the assessee are partly allowed for statistical purposes and the appeals of the revenue are dismissed

ITA 1223/KOL/2017[2011-12]Status: DisposedITAT Kolkata10 May 2024AY 2011-12

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 115JSection 143(1)Section 37

price as on the date of grant of such stock option. During the year, the assessee has determined Rs. 314,23,65,720/- as employee compensation cost accruing for the year based on the vesting period of the ESOPs which was duly disclosed in the Annual Account for the said year. The assessee claims to be entitled to the deduction