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11 results for “transfer pricing”+ Section 155(15)clear

Sorted by relevance

Mumbai297Delhi187Cochin61Chandigarh60Ahmedabad57Bangalore38Chennai36Jaipur36Hyderabad27Raipur19Surat17Rajkot16Pune11Kolkata11Nagpur10Cuttack7Visakhapatnam6Lucknow5Jodhpur3Indore3Jabalpur2Guwahati2Amritsar2

Key Topics

Section 143(3)9Addition to Income9Section 50C7Section 2636Section 92C6Section 2505Section 80I5Long Term Capital Gains5Section 143(2)

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

transfer pricing adjustment stands deleted. Consequently, ground nos. 6 the assessee’s appeal stand allowed. 023. The issue raised in ground no.7, is against the disallowance of expenses of ₹7,50,50,000/- u/s 14A of the Act in relation to earning of exempt income. 024. The facts in brief are that during the year under consideration, the appellant

4
Section 56(2)(X)3
Transfer Pricing3
Deduction2

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

In the result, the appeal filed by the assessee is partly allowed

ITA 1875/KOL/2024[2020-2021]Status: DisposedITAT Kolkata11 Dec 2025AY 2020-2021

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(3)Section 144Section 144C(5)Section 92BSection 92CSection 92C(3)

Price adjustment on account of corporate guarantee fee and grant consequential relief to the assessee. Hence Ground Nos. 2 and 3 of the appeal are partly allowed. 7. Ground no. 4 relates to non-grant of deduction of Rs. 52,91,000/- u/s 80G of the Act. The Ld. AO did not allow the deduction holding as under

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)

price of the flat and the value as\nper Stamp Valuation Authority. However, as a matter of fact the property was purchased\nin the earlier year as observed by us hereinabove in view of the payments being made\nin entirety in the earlier financial year and the details of payments have already\nextracted hereinabove. We note that the first payment

DCIT, CC-1(3), KOLKATA, KOLKATA vs. M/S. A R SULPHONATES PVT. LTD., KOLKATA

In the result, appeal of the revenue is dismissed

ITA 570/KOL/2022[2017-2018]Status: DisposedITAT Kolkata22 Mar 2024AY 2017-2018

Bench: Shri Sonjoy Sarma & Shri Girish Agrawalassessment Year: 2017-18

For Appellant: Shri Rajeeva Kumar, Advocate & ShriFor Respondent: Shri B. K. Singh, JCIT, Sr. DR
Section 143(3)Section 50C

price which the stamp valuation authority would have, notwithstanding anything to the contrary contained in any other law for the time being in force, adopted or assessed, if it were referred to such authority for the purposes of the payment of stamp duty.] (3) Subject to the provisions contained in sub-section (2), where the value ascertained under sub-section

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)

15) of section 155 shall, as far as may be, apply in relation to the stamp duty\nvalue of such property for the purpose of sub-clause (b) as they apply for valuation of capital asset\nunder those sections:\nProvided further that this clause shall not apply to any sum of money or any property received—\n(a) from

IVL DHUNSERI PETROCHEM INDUSTRIES PRIVATE LIMITED,KOLKATA vs. D.C.I.T., CIRCLE - 11(1), KOLKATA, KOLKATA

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

ITA 1712/KOL/2024[2020-2021]Status: DisposedITAT Kolkata24 Apr 2025AY 2020-2021

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyआयकर अपील सं/Ita No.1712/Kol/2024 (नििाारण वर्ा / Assessment Year : 2020-2021) Ivl Dhunseri Petrochem Vs Dcit, Circle-11(1), Kolkata Industries Pvt. Ltd. Dhunseri House, 4A Woodburn Park, L.R.Sarani, West Bengal-700020 Pan No. :Aafcd 5214 M (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri Akkal Dudhewala, Ca & Vidhi Ladia, Ca राजस्व की ओर से /Revenue By : Pradip Kumar Mondal, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 19/03/2025 घोषणा की तारीख/Date Of Pronouncement : 23/04/2025 आदेश / O R D E R Rajesh Kumar, Am : This Is An Appeal Filed By The Assessee Against The Order Dated 26/07/2024, Passed By The Assessment Unit, National Faceless Assessment Centre U/S.143(3) R.W.S.144C(13) R.W.S.144B Of The Act, For The Assessment Year 2020-2021 On The Following Grounds :- 1.(A) For That On The Facts & In The Circumstances Of The Case & In Law, The Tpo Erred In Making A Downward Adjustment Of Rs.24,72,79,392/- In Respect Of The Transfer Value Of Power By The Captive Power Plant At Haldia, West Bengal. (B) For That On The Facts & In The Circumstances Of The Case & In Law, The Methodology Followed By The Assessee To Benchmark The Arm'S Length Value Of The Power Transferred By The Eligible Unit To The Non-Eligible Unit Fulfilled The Internal Cup Parameters & In That View Of The Matter The Transfer Pricing Adjustment Made By The Tpo Was Impermissible On The Given Facts & In Law. (C) For That On The Facts & In The Circumstances Of The Case & In Law, The Manner In Which The Drp/Tpo Has Benchmarked

For Appellant: Shri Akkal Dudhewala, CA and VidhiFor Respondent: Pradip Kumar Mondal, CIT-DR
Section 115Section 143(3)Section 234ASection 270ASection 80ISection 92C

price of electricity sold by it to its paper unit, the same could not be availed of by the assessee. The electricity generated was sold by the assessee entirely to its paper unit. There was no surplus electricity to be supplied to the State Electricity Board and consequently, there was no contract between the assessee and the State Electricity Board

BRITANNIA INDUSTRIES LTD,KOLKATA vs. DCIT, CIR-7(1), KOLKATA

In the result, the appeal of the assessee is allowed

ITA 462/KOL/2023[2018-19]Status: DisposedITAT Kolkata06 Mar 2024AY 2018-19

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma

Section 139(1)Section 143(3)Section 263Section 35(1)(i)Section 43BSection 56(2)(x)Section 80J

transfer of leasehold interest/rights, which is in consonance with the provisions of section 50C and section 56(2)(vii) of the Act. In defence of his argument, ld. A.R. relied on the following decisions:- (i) Green Fields Hotels & Estates (389 ITR 68) (Bom HC); (ii) Dy. CIT v. Tejinder Singh (19 taxmann.com 4) (ITAT Kolkata) (iii) Atul G Puranik

PINKY AGARWAL ,KOLKATA vs. ACIT, CC-3(1), KOLKATA , KOLKATA

In the result, all the appeals of the assessee(s) are allowed as per the terms indicated hereinabove

ITA 984/KOL/2018[2014-15]Status: DisposedITAT Kolkata14 Jul 2023AY 2014-15

Bench: Sri Sanjay Garg & Dr. Manish Borad

Section 143(2)Section 250

price chart of Blue Circle Services Ltd., wherein there is a steep upward trend from 2011-12 onwards then a downward trend which goes up to the end of 2013 and again there is an increase in trend during 2013-14 but not to that extent of the past trend of steep increase. The claim of the assessee is that

PRATIK AGARWAL BENEFICIARY TRUST ,KOLKATA vs. ACIT, C.C.-3(1), , KOLKATA

In the result, all the appeals of the assessee(s) are allowed as per the terms indicated hereinabove

ITA 2068/KOL/2018[2014-15]Status: DisposedITAT Kolkata14 Jul 2023AY 2014-15

Bench: Sri Sanjay Garg & Dr. Manish Borad

Section 143(2)Section 250

price chart of Blue Circle Services Ltd., wherein there is a steep upward trend from 2011-12 onwards then a downward trend which goes up to the end of 2013 and again there is an increase in trend during 2013-14 but not to that extent of the past trend of steep increase. The claim of the assessee is that

M/S. GATEWAY FINANCIAL SERVICES LTD., ,KOLKATA vs. ACIT, CC - 3(1), KOLKATA , KOLKATA

In the result, all the appeals of the assessee(s) are allowed as per the terms indicated hereinabove

ITA 982/KOL/2018[2014-15]Status: DisposedITAT Kolkata14 Jul 2023AY 2014-15

Bench: Sri Sanjay Garg & Dr. Manish Borad

Section 143(2)Section 250

price chart of Blue Circle Services Ltd., wherein there is a steep upward trend from 2011-12 onwards then a downward trend which goes up to the end of 2013 and again there is an increase in trend during 2013-14 but not to that extent of the past trend of steep increase. The claim of the assessee is that

M/S. NISHIT AGARWAL BENEFICIARY TRUST ,KOLKATA vs. ACIT, CC - 3(1), KOLKATA , KOLKATA

In the result, all the appeals of the assessee(s) are allowed as per the terms indicated hereinabove

ITA 983/KOL/2018[2014-15]Status: DisposedITAT Kolkata14 Jul 2023AY 2014-15

Bench: Sri Sanjay Garg & Dr. Manish Borad

Section 143(2)Section 250

price chart of Blue Circle Services Ltd., wherein there is a steep upward trend from 2011-12 onwards then a downward trend which goes up to the end of 2013 and again there is an increase in trend during 2013-14 but not to that extent of the past trend of steep increase. The claim of the assessee is that