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14 results for “transfer pricing”+ Section 391clear

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Key Topics

Section 14A17Section 50C15Addition to Income13Section 80I10Disallowance9Deduction7Section 143(2)6Section 115J6Section 2506

TATA CONSUMER PRODUCTS LIMITED,KOLKATA vs. DCIT, CIR.-4(1), KOLKATA

In the result, the appeal for AY 2014-15 is partly allowed

ITA 372/KOL/2021[2014-15]Status: DisposedITAT Kolkata17 Sept 2024AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishraassessment Years: 2014-15 & Assessment Years: 2015-16

For Appellant: Sriram Sashdari, ARFor Respondent: Rakesh Kumar Das, CIT, DR
Section 250Section 43(6)Section 50CSection 50C(2)Section 928

391 to 394 of the Companies Act, 1956 effective from 18 May 2015. To give effect to the amalgamation, a revised return was filed on 26th November 2015 declaring total income of Rs. 4,62,27,29,010/- under normal provisions and Rs. 6,07,14,22,413/- un- der the provisions of Section 115JB of the Act and claiming

Section 143(3)6
Section 686
Transfer Pricing6

TATA CONSUMER PRODUCTS LIMITED,KOLKATA vs. DCIT, CIR.-4(1), KOLKATA

In the result, the appeal for AY 2014-15 is partly allowed

ITA 373/KOL/2021[2015-16]Status: DisposedITAT Kolkata17 Sept 2024AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishraassessment Years: 2014-15 & Assessment Years: 2015-16

For Appellant: Sriram Sashdari, ARFor Respondent: Rakesh Kumar Das, CIT, DR
Section 250Section 43(6)Section 50CSection 50C(2)Section 928

391 to 394 of the Companies Act, 1956 effective from 18 May 2015. To give effect to the amalgamation, a revised return was filed on 26th November 2015 declaring total income of Rs. 4,62,27,29,010/- under normal provisions and Rs. 6,07,14,22,413/- un- der the provisions of Section 115JB of the Act and claiming

THE INDRA COMPANY LIMITED(AS SAUMYA TRADE & FISCAL SERVICES P. LTD. MERGED INTO THE INDRA CO. LTD.),KOLKATA vs. I.T.O., WARD - 12(3),, KOLKATA

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

ITA 2038/KOL/2024[2016-2017]Status: DisposedITAT Kolkata29 May 2025AY 2016-2017
Section 143(2)Section 250Section 48

sections 391 to 394 of the Companies Act,\n1956, pursuant to which the equity shares of the issuer were\nlisted, as the case may be; or\n(b) the average of the weekly high and low of the volume weighted\naverage prices closing prices of the related equity shares quoted\non the recognised stock exchange during the period shares have

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 when sold by the assessee or power generation station to the State Electricity Board. The Hon'ble Apex Court noted that the price at which surplus power was supplied by the assessee to the State Electricity Board was determined entirely by State Electricity Board in terms of statutory regulations and contractual terms and that such a price

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 when sold by the assessee or power generation station to the State Electricity Board. The Hon'ble Apex Court noted that the price at which surplus power was supplied by the assessee to the State Electricity Board was determined entirely by State Electricity Board in terms of statutory regulations and contractual terms and that such a price

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 when sold by the assessee or power generation station to the State Electricity Board. The Hon'ble Apex Court noted that the price at which surplus power was supplied by the assessee to the State Electricity Board was determined entirely by State Electricity Board in terms of statutory regulations and contractual terms and that such a price

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 when sold by the assessee or power generation station to the State Electricity Board. The Hon'ble Apex Court noted that the price at which surplus power was supplied by the assessee to the State Electricity Board was determined entirely by State Electricity Board in terms of statutory regulations and contractual terms and that such a price

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 when sold by the assessee or power generation station to the State Electricity Board. The Hon'ble Apex Court noted that the price at which surplus power was supplied by the assessee to the State Electricity Board was determined entirely by State Electricity Board in terms of statutory regulations and contractual terms and that such a price

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

391 (Kol) and Ritz Suppliers Pvt. ltd. (2020) 113 taxmann.com 349 (Kol). 3.8. Ld. CIT(A) after considering the facts of the case and submissions made by the assessee noted about the undisputed fact that only the leasehold rights in an industrial plot of land has been transferred to SMI for a total consideration of Rs. 2 Cr. He further

GRAPHITE INDIA LTD.,KOLKATA vs. PR.CIT-4, KOLKATA

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

ITA 1013/KOL/2019[2014-15]Status: DisposedITAT Kolkata03 Jul 2023AY 2014-15

Bench: Shri Rajpal Yadav, Vice- & Shri Rajesh Kumar

Section 115JSection 143(3)Section 14ASection 263Section 263(1)Section 40A(2)(b)

Transfer Pricing Officer. Moreover the Id AR has put up clarificatory details as well as reasoning for apparent discrepancy in disclosure. However what needs to be considered is that neither the said clarification was sought by the AO nor any enquiry was made by the AO to check the correctness of specific domestic transactions. The issue of reference

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

transferred out as subscribed by 18 such entities consisting of private limited companies and individuals, with apparently no credible business or creditworthiness to hold shares of such value. So what is the motive of the entire transaction? Why the churning of balance sheet was necessary by showing allotment of shares fancily priced without basis? Who are these 18 entities whose

THE INDIAN STEEL & WIRE PRODUCTS LTD.,KOLKATA vs. ITO, WD-3(2), KOLKATA, KOLKATA

In the result, appeal of the assessee for Assessment Year 2007-

ITA 1128/KOL/2016[2007-08]Status: HeardITAT Kolkata21 Apr 2023AY 2007-08

Bench: Shri Sonjoy Sarma, Hon’Ble & Shri Girish Agrawal, Hon’Ble

For Appellant: Shri Akshay Ringasia, C.AFor Respondent: Smt. Ranu Biswas, Addl. CIT, Sr. D/R
Section 250

price of the product and the reliable estimate of the expenditure towards such warranty was allowable as the business expenditure u/s 37(1) ". 8. The ld. Counsel for assessee submitted that, it is an undisputed fact that the said provisions had been created on a scientific basis. It is also a settled matter that the said provisions are allowable

THE INDIAN STEEL & WIRE PRODUCTS LTD.,KOLKATA vs. ITO, WD-3(2), KOLKATA, KOLKATA

In the result, appeal of the assessee for Assessment Year 2007-

ITA 1129/KOL/2016[2010-2011]Status: HeardITAT Kolkata21 Apr 2023AY 2010-2011

Bench: Shri Sonjoy Sarma, Hon’Ble & Shri Girish Agrawal, Hon’Ble

For Appellant: Shri Akshay Ringasia, C.AFor Respondent: Smt. Ranu Biswas, Addl. CIT, Sr. D/R
Section 250

price of the product and the reliable estimate of the expenditure towards such warranty was allowable as the business expenditure u/s 37(1) ". 8. The ld. Counsel for assessee submitted that, it is an undisputed fact that the said provisions had been created on a scientific basis. It is also a settled matter that the said provisions are allowable

M/S. BANKURA DISTRICT CENTRAL CO.OPETATIVE BANK LTD. ,BANKURA vs. DCIT, CIR-3, BANKURA. , BANKURA

In the result, ITA No. 1479/KOL/2023 is allowed for statistical purpose

ITA 1479/KOL/2023[2013-14]Status: DisposedITAT Kolkata11 Mar 2024AY 2013-14

Bench: Sri Rajesh Kumar & Sri Anikesh Banerjee

Section 143(3)Section 250

price inclusive of any accrued interest, the entire purchase consideration is in the nature of capital outlay. Therefore, any interest element included in the purchase consideration is not allowable as expenditure against income accruing on those securities. In view of the aforesaid decision of the Hon'ble Apex court amortization of premium paid on Government securities amounting to Rs.46