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7 results for “transfer pricing”+ Section 36(1)(va)clear

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Mumbai82Chandigarh64Delhi55Chennai27Ahmedabad26Hyderabad18Jaipur14Jodhpur10Kolkata7Raipur6Bangalore6Pune4Surat3Lucknow3Cuttack2Cochin1Indore1Visakhapatnam1

Key Topics

Section 36(1)(va)12Section 143(3)9Section 14A8Transfer Pricing6Disallowance6Section 139(1)4Section 2634Section 2(24)(x)3Section 115J3Section 2(22)(e)

DCIT, CIR. 5(1), KOLKATA vs. KARAM CHAND THAPAR & BROS COAL SALES LTD., KOLKATA

In the result, appeal of the Revenue for AY 2015-16 is partly allowed and appeal for AY 2016-17 is dismissed

ITA 321/KOL/2021[2016-17]Status: DisposedITAT Kolkata28 Feb 2023AY 2016-17

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Girish Agrawali.T.A. Nos. 320 & 321/Kol/2021 Assessment Years: 2015-16 & 2016-17 Deputy Commissioner Of Income Tax,........Appellant Circle-5(1), Kolkata, Aayakar Bhawan, P-7, Chowringhee Square, Kolkata-700069 -Vs.- Karam Chand Thapar & Bros. Coal Sales Limited,........................Respondent 25, Brabourne Road, Kolkata-700001 [Pan;Aabck1281H] Appearances By: Shri G. Hukugha Sema, Cit, Appeared On Behalf Of The Revenue Shri N.S. Saini, A.R., Appeared On Behalf Of The Assessee Date Of Concluding The Hearing : January 02, 2023 Date Of Pronouncing The Order : February 28, 2023 O R D E R

Section 139(1)Section 143(3)Section 36(1)Section 36(1)(va)Section 43B

36(1)(va) of the Act to only those payments made beyond the due date of filing return under section 139(1) of the Act. 4. From the perusal of grounds, broadly two issues are involved, one relating to Transfer Pricing

3
Double Taxation/DTAA2
TDS2

DCIT, CIR. 5(1), KOLKATA vs. KARAM CHAND THAPAR & BROS COAL SALES LTD., KOLKATA

In the result, appeal of the Revenue for AY 2015-16 is partly allowed and appeal for AY 2016-17 is dismissed

ITA 320/KOL/2021[2015-16]Status: DisposedITAT Kolkata28 Feb 2023AY 2015-16

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Girish Agrawali.T.A. Nos. 320 & 321/Kol/2021 Assessment Years: 2015-16 & 2016-17 Deputy Commissioner Of Income Tax,........Appellant Circle-5(1), Kolkata, Aayakar Bhawan, P-7, Chowringhee Square, Kolkata-700069 -Vs.- Karam Chand Thapar & Bros. Coal Sales Limited,........................Respondent 25, Brabourne Road, Kolkata-700001 [Pan;Aabck1281H] Appearances By: Shri G. Hukugha Sema, Cit, Appeared On Behalf Of The Revenue Shri N.S. Saini, A.R., Appeared On Behalf Of The Assessee Date Of Concluding The Hearing : January 02, 2023 Date Of Pronouncing The Order : February 28, 2023 O R D E R

Section 139(1)Section 143(3)Section 36(1)Section 36(1)(va)Section 43B

36(1)(va) of the Act to only those payments made beyond the due date of filing return under section 139(1) of the Act. 4. From the perusal of grounds, broadly two issues are involved, one relating to Transfer Pricing

MECLEOD RUSSEL INDIA LTD.,KOLKATA vs. A.C.I.T., CIRCLE - 4(1), KOLKATA, KOLKATA

The appeals of the assessee are partly allowed

ITA 454/KOL/2022[2017-2018]Status: DisposedITAT Kolkata17 Jun 2025AY 2017-2018

Bench: the due date of filing of return u/s 139(1) of the Act.

Section 115JSection 139(1)Section 143(3)Section 14ASection 2(24)(x)Section 36(1)(va)Section 37

transfer pricing adjustment of Rs.2,98,142/- made on account of the purchase of goods by the appellant is vitiated by an error in law and fact and is therefore liable to be deleted. 4. For that the Assessing Officer erred in law and on facts in making disallowance of Rs.30,85,965/- u/s 36(1)(va) read with section

MCLEOD RUSSEL INDIA LIMITED,KOLKATA vs. A.C.I.T., CIRCLE-4(1), KOLKATA, KOLKATA

The appeals of the assessee are partly allowed

ITA 458/KOL/2022[2018-2019]Status: DisposedITAT Kolkata17 Jun 2025AY 2018-2019

Bench: the due date of filing of return under Section 139(1) of the Act.

Section 115JSection 139(1)Section 143(3)Section 14ASection 2(24)(x)Section 36(1)(va)Section 37

transfer pricing adjustment of Rs.2,98,142/- made on account of the purchase of goods by the appellant is vitiated by an error in law and fact and is therefore liable to be deleted. 4. For that the Assessing Officer erred in law and on facts in making disallowance of Rs.30,85,965/- u/s 36(1)(va) read with section

NORMURA RESEARCH INSTITURE FINANCIAL TECHNOLOGIES INDIA PRIVATE LIMITED,KOLKATA vs. ACIT,CIRCLE-2(2), KOL, KOLKATA

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

ITA 204/KOL/2017[2012-13]Status: DisposedITAT Kolkata09 Feb 2023AY 2012-13

Bench: Shri Sanjay Garg & Shri Girish Agrawalassessment Year: 2012-13

For Appellant: Shri J. P. Khaitan, Sr. Counsel & ShriFor Respondent: Shri Amal Kamat, CIT, DR
Section 115JSection 143(3)Section 144CSection 144C(5)

36. Before us, on the issue of working capital adjustment, the AR submitted that the ITAT in its order had observed, "The assessee has also requested for working capital adjustment. The case of the assessee is that working capital does have an impact on the profitability of the company and more accounts receivable in case of a company would mean

BENGAL SHRACHI HOUSING DEVELOPMENT LIMITED,KOLKATA vs. ACIT, CIR. 5(1), KOLKATA

In the result, the appeal of assessee is dismissed

ITA 251/KOL/2022[2017-18]Status: DisposedITAT Kolkata02 Jan 2023AY 2017-18

Bench: Shri Sanjay Garg & Shri Manish Boradआयकर अपील सं.य/ Assessment Year:2017-18 बनाम Bengalshrachi Acit, Cir-5(1), Kolkata Housingdevelopment Aaykar Bhawan V/S. Ltd. P-7 Chowringhee Square, 686 Shrachi Tower, Kolkata-700 069. Anandapur,E.M Bypass, Kolkata-700 107. Pan: Aabcb2808F अपीलाथ" /Appellant ""यथ" /Respondent ..

Section 143(2)Section 143(3)Section 14ASection 2Section 2(22)Section 2(22)(e)Section 2(24)(x)Section 263

36(1)(va) of the Act of Rs. 1,34,735/-. Subsequently, the assessment records were called for by the ld.PCIT and after examining of the same the ld. PCIT observed that assessee has received loan sum of 2. AY 2017-18 Bengal Shrachi Housing Development Ltd. Rs. 4,66,69,103/- from M/s. Rosedala Developers P.Ltd (In short

MCLEOD RUSSEL INDIA LTD.,,KOLKATA vs. DCIT, CIRCLE 4(1),, KOLKATA

In the result, the appeal of the assessee is partly allowed

ITA 384/KOL/2025[2020-21]Status: DisposedITAT Kolkata25 Aug 2025AY 2020-21

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 143(1)Section 144C(1)Section 14A

Transfer pricing adjustment of Rs. 5,67,942/- in respect of Corporate Guarantee Fee: It is pertinent to mention here that the AO has charged 0.74% as corporate guarantee fee on the account of corporate guarantee fee given by the assessee against the loan given to its associates concern. The Ld. A.R placed reliance on the decision of co-ordinate