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55 results for “transfer pricing”+ Section 131(1)clear

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Key Topics

Addition to Income50Section 14745Section 14844Section 26330Section 115J26Condonation of Delay25Section 143(3)24Section 6823Section 14A

EXIMCORP INDIA PRIVATE LIMITED. ,KOLKATA vs. ACIT,CIR-5(2),KOLKATA. , KOLKATA

In the result, the appeal of the assessee is dismissed

ITA 701/KOL/2023[2015-16]Status: DisposedITAT Kolkata05 Aug 2024AY 2015-16

Bench: Sri Rajpal Yadav, Vice- & Sri Sanjay Awasthi

Section 115JSection 195Section 195(1)Section 2Section 40

131 (Andhra Pradesh), wherein it has been said that if interest is debited to the account of an Indian company by a bank to recoup the interest charged to it by the discounting bank, then the provisions of Section 195 of the Act will not apply. It has been further averred that the appellant is not the person responsible

EXIMCORP INDIA (P) LTD. ,KOLKATA vs. ACIT,CIR-5(2),KOLKATA. , KOLKATA

In the result, the appeal of the assessee is dismissed

Showing 1–20 of 55 · Page 1 of 3

22
Section 143(2)17
Disallowance17
Deduction11
ITA 702/KOL/2023[2016-17]Status: DisposedITAT Kolkata05 Aug 2024AY 2016-17

Bench: Sri Rajpal Yadav, Vice- & Sri Sanjay Awasthi

Section 115JSection 195Section 195(1)Section 2Section 40

131 (Andhra Pradesh), wherein it has been said that if interest is debited to the account of an Indian company by a bank to recoup the interest charged to it by the discounting bank, then the provisions of Section 195 of the Act will not apply. It has been further averred that the appellant is not the person responsible

DCIT, CIRCLE-6(1), KOLKATA vs. M/S. IFB AGRO INDUSTRIES LTD., KOLKATA

In the result, both the appeals filed by the revenue in ITA No

ITA 491/KOL/2019[2014-15]Status: DisposedITAT Kolkata09 Feb 2024AY 2014-15

Bench: Dr. Manish Borad&Shri Anikesh Banerjee]

Section 143(3)Section 14ASection 250Section 80ISection 92C

transfer pricing adjustment made for deduction u/s 80IA of the Act raised by the Revenue are dismissed. 8. Mr. Khaitan further invited our attention in the order of Hon’ble Apex Court in the case of CIT vs. Jindal Steel & Power Ltd. (supra) the relevant paragraphs are reproduced as below: “27. Another way of looking at the issue

DCIT, CIRCLE-6(1), KOLKATA vs. M/S. IFB AGRO INDUSTRIES LTD., KOLKATA

In the result, both the appeals filed by the revenue in ITA No

ITA 490/KOL/2019[2013-14]Status: DisposedITAT Kolkata09 Feb 2024AY 2013-14

Bench: Dr. Manish Borad&Shri Anikesh Banerjee]

Section 143(3)Section 14ASection 250Section 80ISection 92C

transfer pricing adjustment made for deduction u/s 80IA of the Act raised by the Revenue are dismissed. 8. Mr. Khaitan further invited our attention in the order of Hon’ble Apex Court in the case of CIT vs. Jindal Steel & Power Ltd. (supra) the relevant paragraphs are reproduced as below: “27. Another way of looking at the issue

VESHNAWY VYAPAAR PVT. LTD.,KOLKATA vs. ITO, WARD - 9(2), KOLKATA , KOLKATA

In the result, appeal of the assessee is dismissed

ITA 887/KOL/2018[2010-11]Status: DisposedITAT Kolkata03 Oct 2023AY 2010-11

Bench: Shri Rajpal Yadav, Vice- & Dr. Manish Borad

Section 133(6)Section 143(2)Section 143(3)Section 263Section 68

131 of the Act to all the share subscribers. Thereafter when the jurisdiction was transferred to Ward-9(2), again notice under section 142(1) of the Act was issued on 09.01.2015, but thereafter the assessee did not comply and the assessment was completed. The above details of 12 Assessment Year : 2010-2011 Veshnawy Vyapaar Pvt. Limited the transfer

MADHUBAN DEALERS PVT. LTD. PRESENTLY KNOWN AS MADHUBAN DEALERS LLP,KOLKATA vs. PCIT-13, KOLKATA

In the result, the appeal of assessee allowed

ITA 273/KOL/2022[2010-11]Status: DisposedITAT Kolkata07 Nov 2023AY 2010-11

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 143(1)Section 143(3)Section 144Section 147Section 148Section 154Section 263Section 68

131 of the Act was issued on 24.10.2016 to the director of the assessee company fixing the date of hearing on 27.07.2016. And pursuant to the summons, the Director Shri Rajeev Kumar appeared with photo identity proof, and his statement was recorded by the AO and placed in the records. According to AO (which he records in the reassessment order

ITO, WARD-5(1), KOLKATA vs. M/S VISHNU DISTRIBUTORS PVT LTD, KOLKATA

In the result, the appeal of the Revenue is devoid of any merit, hence dismissed

ITA 50/KOL/2022[2012-13]Status: DisposedITAT Kolkata20 May 2024AY 2012-13

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumari.T.A. No. 50/Kol/2022 Assessment Year: 2012-2013

Section 131Section 14ASection 68

1) were issued and served upon the assessee. The ld. Assessing Officer has observed that the assessee-company had issued 39,860 equity shares at the rate of Rs.10/- each and premium of Rs.990/-. It has received share capital of Rs.3,98,44,628/-. The ld. Assessing Officer has observed that he has issued notices under section 131

PCBL LIMITED,KOLKATA vs. A.C.I.T., CIRCLE - 11(1),, KOLKATA

In the result, all the appeals of the revenue are dismissed and the appeal filed by the assessee is partly allowed for statistical purposes

ITA 2034/KOL/2024[2020-2021]Status: DisposedITAT Kolkata10 Jun 2025AY 2020-2021

Bench: Shri Pradip Kumar Choubey&Shri Sanjay Awasthi]

Section 115JSection 143(1)Section 143(2)Section 14ASection 35Section 35(2)(ab)Section 37Section 80GSection 80ISection 92C

transfer of power at the rate at which the manufacturing unit was procuring power from the Grid. On further appeal by the Revenue, the Hon'ble Calcutta High Court after taking note of the decision of CIT Vs Jindal Steel & Power Ltd (supra) wherein their earlier decision in the case of ITC Ltd (supra) was reversed, since upheld the decision

PRAMOD LAKRA, DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 11(1), KOLKATA, KOLKATA vs. PHILLIPS CARBON BLACK LTD, KOLKATA

In the result, all the appeals of the revenue are dismissed and the appeal filed by the assessee is partly allowed for statistical purposes

ITA 2456/KOL/2024[2017-18]Status: DisposedITAT Kolkata10 Jun 2025AY 2017-18

Bench: Shri Pradip Kumar Choubey&Shri Sanjay Awasthi]

Section 115JSection 143(1)Section 143(2)Section 14ASection 35Section 35(2)(ab)Section 37Section 80GSection 80ISection 92C

transfer of power at the rate at which the manufacturing unit was procuring power from the Grid. On further appeal by the Revenue, the Hon'ble Calcutta High Court after taking note of the decision of CIT Vs Jindal Steel & Power Ltd (supra) wherein their earlier decision in the case of ITC Ltd (supra) was reversed, since upheld the decision

PRAMOD LAKRA,DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -11(1), KOLKATA, KOLKATA vs. PHILIPS CARBON BLACK LTD , KOLKATA

In the result, all the appeals of the revenue are dismissed and the appeal filed by the assessee is partly allowed for statistical purposes

ITA 2459/KOL/2024[2021-22]Status: DisposedITAT Kolkata10 Jun 2025AY 2021-22

Bench: Shri Pradip Kumar Choubey&Shri Sanjay Awasthi]

Section 115JSection 143(1)Section 143(2)Section 14ASection 35Section 35(2)(ab)Section 37Section 80GSection 80ISection 92C

transfer of power at the rate at which the manufacturing unit was procuring power from the Grid. On further appeal by the Revenue, the Hon'ble Calcutta High Court after taking note of the decision of CIT Vs Jindal Steel & Power Ltd (supra) wherein their earlier decision in the case of ITC Ltd (supra) was reversed, since upheld the decision

PRAMOD LAKRA, DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-11(1), KOLKATA, KOLKATA vs. PHILLIPS CARBON BLACK LTD, KOLKATA

In the result, all the appeals of the revenue are dismissed and the appeal filed by the assessee is partly allowed for statistical purposes

ITA 2458/KOL/2024[2020-21]Status: DisposedITAT Kolkata10 Jun 2025AY 2020-21

Bench: Shri Pradip Kumar Choubey&Shri Sanjay Awasthi]

Section 115JSection 143(1)Section 143(2)Section 14ASection 35Section 35(2)(ab)Section 37Section 80GSection 80ISection 92C

transfer of power at the rate at which the manufacturing unit was procuring power from the Grid. On further appeal by the Revenue, the Hon'ble Calcutta High Court after taking note of the decision of CIT Vs Jindal Steel & Power Ltd (supra) wherein their earlier decision in the case of ITC Ltd (supra) was reversed, since upheld the decision

PRAMOD LAKRA,DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 11(1), KOLKATA, KOLKATA vs. PHILLIPS CARBON BLACK LTD., KOLKATA

In the result, all the appeals of the revenue are dismissed and the appeal filed by the assessee is partly allowed for statistical purposes

ITA 2457/KOL/2024[2018-19]Status: DisposedITAT Kolkata10 Jun 2025AY 2018-19

Bench: Shri Pradip Kumar Choubey&Shri Sanjay Awasthi]

Section 115JSection 143(1)Section 143(2)Section 14ASection 35Section 35(2)(ab)Section 37Section 80GSection 80ISection 92C

transfer of power at the rate at which the manufacturing unit was procuring power from the Grid. On further appeal by the Revenue, the Hon'ble Calcutta High Court after taking note of the decision of CIT Vs Jindal Steel & Power Ltd (supra) wherein their earlier decision in the case of ITC Ltd (supra) was reversed, since upheld the decision

D.CI.T.,CENTRAL CIRCLE-4(1), KOLKATA vs. M/S IMPEX FERRO TECH LTD., KOLKATA

In the result, both the appeals filed by the assessee are dismissed as infructuous

ITA 1521/KOL/2019[2014-15]Status: DisposedITAT Kolkata27 Oct 2025AY 2014-15

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 144CSection 145(3)Section 250

section 68 of the IT Act. 8. That on the facts and in the circumstances of the case the Ld. CIT(A) has erred in deleting the arm's length price adjustment of Rs. 16,10,00,000/- made by the AO/TPO on account of purchase of high ash energy coal by the assessee from its associated enterprises. 9. That

M/S IMPEX FERRO TECH LTD.,KOLKATA vs. A.CI.T.,CENTRAL CIRCLE-4(1), KOLKATA

In the result, both the appeals filed by the assessee are dismissed as infructuous

ITA 1640/KOL/2019[2014-15]Status: DisposedITAT Kolkata27 Oct 2025AY 2014-15

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 144CSection 145(3)Section 250

section 68 of the IT Act. 8. That on the facts and in the circumstances of the case the Ld. CIT(A) has erred in deleting the arm's length price adjustment of Rs. 16,10,00,000/- made by the AO/TPO on account of purchase of high ash energy coal by the assessee from its associated enterprises. 9. That

NAVANSH VINIMAY PVT. LTD.,KOLKATA vs. I.T.O., WARD - 8(2), KOLKATA, KOLKATA

In the result, the appeal of the assessee is dismissed

ITA 724/KOL/2022[2012-2013]Status: DisposedITAT Kolkata30 May 2025AY 2012-2013

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 142(1)Section 143Section 143(2)Section 143(3)Section 147Section 148Section 151Section 250

131 of the Act and concluded that the assessee had pre-arranged accommodation entries to the tune of Rs. 63,76,486/- through the entry operators who facilitate such accommodation entries on receipt of commission. As reported by the Directorate of Income Tax (Inv.), the entry operators charge a commission @1% of the amount of loss on the sale

JCIT(OSD), CIR011(1), KOLKATA vs. M/S. PHILIPS CARBON BLACK LTD. , KOLKATA

In the result, the appeal of the Revenue is dismissed

ITA 234/KOL/2023[2014-15]Status: DisposedITAT Kolkata28 Aug 2025AY 2014-15

Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumari.T.A. No.234/Kol/2023 Assessment Year: 2014-15 Jcit(Osd), Circle-11(1), Kolkata........................…...........................……….……Appellant Vs. M/S Philips Carbon Black Ltd.............…..….…..….........……........……...…..…..Respondent Duncan House, 31 Netaji Subhas Road, Kol-1. [Pan: Aabcp5762E] Appearances By: Shri Praveen Kishore, Cit-Dr, Appeared On Behalf Of The Appellant. Shri Akkal Dudhewala, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : June 30, 2025 Date Of Pronouncing The Order : August 29Th, 2025 Order Per Rajesh Kumar:

Section 144CSection 250Section 32(1)Section 32(1)(ii)Section 32(1)(iia)Section 80Section 80I

Section 80IA(8) of the Act. 8. The Ld. AR for the assessee, at the onset, submitted that, the assessee had declared overall business loss of Rs.(-) 131,04,88,074/- in the return of income and accordingly did not make any claim qua profit as deduction u/s 80-IA of the Act in respect of the profits derived

SAMRAT FINVESTORS PRIVATE LIMITED,KOLKATA vs. DCIT, CENT. CIR. 4(2), , KOLKATA

In the result, the appeals of the assessee are partly allowed

ITA 1037/KOL/2025[2015-2016]Status: DisposedITAT Kolkata16 Oct 2025AY 2015-2016

Bench: Shri Rajesh Kumar, Am & Shrigeorge Mathan, Jm

For Appellant: Shri Soumitra Choudhury, ARFor Respondent: Shri Sanat Kumar Raha, DR
Section 131Section 143(3)Section 263Section 68

131 and their statements have been recorded and all the evidences with paper books regard to the receipt of the share application money as well as the source thereof was explained and kept on record after due perusal and examination mentioned in the assessment order, as such the finding of Ld. CIT(A) is completely arbitrary, unjustified and illegal

SAMRAT FINVESTORS PRIVATE LIMITED,KOLKATA vs. DCIT, CENT. CIR. 4(2), , KOLKATA

In the result, the appeals of the assessee are partly allowed

ITA 1036/KOL/2025[2014-2015]Status: DisposedITAT Kolkata16 Oct 2025AY 2014-2015

Bench: Shri Rajesh Kumar, Am & Shrigeorge Mathan, Jm

For Appellant: Shri Soumitra Choudhury, ARFor Respondent: Shri Sanat Kumar Raha, DR
Section 131Section 143(3)Section 263Section 68

131 and their statements have been recorded and all the evidences with paper books regard to the receipt of the share application money as well as the source thereof was explained and kept on record after due perusal and examination mentioned in the assessment order, as such the finding of Ld. CIT(A) is completely arbitrary, unjustified and illegal

SAMRAT FINVESTORS PRIVATE LIMITED,KOLKATA vs. ITO, WARD 5(2) (NOW DCIT, CENT.CIR. 4(2)), KOLKATA

In the result, the appeals of the assessee are partly allowed

ITA 1035/KOL/2025[2012-2013]Status: DisposedITAT Kolkata16 Oct 2025AY 2012-2013

Bench: Shri Rajesh Kumar, Am & Shrigeorge Mathan, Jm

For Appellant: Shri Soumitra Choudhury, ARFor Respondent: Shri Sanat Kumar Raha, DR
Section 131Section 143(3)Section 263Section 68

131 and their statements have been recorded and all the evidences with paper books regard to the receipt of the share application money as well as the source thereof was explained and kept on record after due perusal and examination mentioned in the assessment order, as such the finding of Ld. CIT(A) is completely arbitrary, unjustified and illegal

SAMRAT FINVESTORS PRIVATE LIMITED,KOLKATA vs. DCIT, CENT. CIR. 4(2), , KOLKATA

In the result, the appeals of the assessee are partly allowed

ITA 1038/KOL/2025[2016-2017]Status: DisposedITAT Kolkata16 Oct 2025AY 2016-2017

Bench: Shri Rajesh Kumar, Am & Shrigeorge Mathan, Jm

For Appellant: Shri Soumitra Choudhury, ARFor Respondent: Shri Sanat Kumar Raha, DR
Section 131Section 143(3)Section 263Section 68

131 and their statements have been recorded and all the evidences with paper books regard to the receipt of the share application money as well as the source thereof was explained and kept on record after due perusal and examination mentioned in the assessment order, as such the finding of Ld. CIT(A) is completely arbitrary, unjustified and illegal