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14 results for “transfer pricing”+ Section 80G(5)(vi)clear

Sorted by relevance

Mumbai48Delhi30Pune20Bangalore19Kolkata14Rajkot10Chennai8Jaipur6Hyderabad4Cochin3Agra2Jodhpur2Indore1Nagpur1Amritsar1Ahmedabad1

Key Topics

Section 14A15Section 115J12Section 92C10Section 80I10Transfer Pricing8Addition to Income8Disallowance6Limitation/Time-bar6Condonation of Delay

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

M/S TDK INDIA PRIVATE LIMITED,KOLKATA vs. DCIT CIRCLE 11(1), KOLKATA, DELHI AND KOLKATA

6
Section 355
Section 143(1)5
Section 143(2)5

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

ITA 2565/KOL/2024[AY 2021-22]Status: DisposedITAT Kolkata05 Dec 2025

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm M/S Tdk India Private Limited Dcit, Circle 11(1), Kolkata Wbidc Growth Centre, Kulia Aayakar Bhawan, P-7 Kanchrapara Road, Po Ns Chowringhee Square, Sanatorium,Kalyani, Nadia, Vs. 6Th Floor, Roomno.18, Kolkata-741251, Kolkata-700069, West Bengal West Bengal (Appellant) (Respondent) Pan No. Aaaci6950Q Assessee By : Shri Arjit Chakraborthy, Ar Revenue By : Shri S.B. Chakraborthy, Dr Date Of Hearing: 14.11.2025 Date Of Pronouncement: 05.12.2025

For Appellant: Shri Arjit Chakraborthy, ARFor Respondent: Shri S.B. Chakraborthy, DR

Transfer Pricing Officer/ Hon'ble DRP 1. 2011-12 Approach accepted by TPO - No adjustment done TNMM 2. 2012-13 Approach accepted by TPO - No adjustment done TNMM 3. 2013-14 Approach accepted by TPO - No adjustment done TNMM 4. 2014-15 Approach accepted by TPO - No adjustment done TNMM 5. 2015-16 Adjustment deleted by TPO post DRP Direction

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

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 Pricing Officer, case was referred to the TPO, consequent to the reference, the TPO forwarded the order u/s 92CA(3) of the Act and downward adjustment to the income of the assessee with respect to 80IA units is computed at Rs. 28,34,57,200/-. The AO after considering the order passed by the TPO and reply submitted

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 Pricing Officer, case was referred to the TPO, consequent to the reference, the TPO forwarded the order u/s 92CA(3) of the Act and downward adjustment to the income of the assessee with respect to 80IA units is computed at Rs. 28,34,57,200/-. The AO after considering the order passed by the TPO and reply submitted

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 Pricing Officer, case was referred to the TPO, consequent to the reference, the TPO forwarded the order u/s 92CA(3) of the Act and downward adjustment to the income of the assessee with respect to 80IA units is computed at Rs. 28,34,57,200/-. The AO after considering the order passed by the TPO and reply submitted

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 Pricing Officer, case was referred to the TPO, consequent to the reference, the TPO forwarded the order u/s 92CA(3) of the Act and downward adjustment to the income of the assessee with respect to 80IA units is computed at Rs. 28,34,57,200/-. The AO after considering the order passed by the TPO and reply submitted

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 Pricing Officer, case was referred to the TPO, consequent to the reference, the TPO forwarded the order u/s 92CA(3) of the Act and downward adjustment to the income of the assessee with respect to 80IA units is computed at Rs. 28,34,57,200/-. The AO after considering the order passed by the TPO and reply submitted

DCIT, CIR-5(1), , KOLKATA vs. M/S COAL INDIA LTD., KOLKATA

ITA 1697/KOL/2019[2014-15]Status: DisposedITAT Kolkata20 Jan 2026AY 2014-15
Section 115J

VI to\nthe Companies Act' is made for the limited purpose of empowering the\nassessing authority to rely upon the authentic statement of accounts of the\ncompany. While so looking into the accounts of the company, an Assessing\nOfficer under the Income-tax Act has to accept the authenticity of the\naccounts with reference to the provisions of the Companies

DCIT, CIRCLE - 5(1), KOLKATA, KOLKATA vs. M/S. COAL INDIA LIMITED , KOLKATA

ITA 623/KOL/2018[2012-13]Status: DisposedITAT Kolkata20 Jan 2026AY 2012-13
Section 115JSection 250

VI to the Companies Act' is made for the limited purpose of empowering the assessing authority to rely upon the authentic statement of accounts of the company. While so looking into the accounts of the company, an Assessing Officer under the Income-tax Act has to accept the authenticity of the accounts with reference to the provisions of the Companies

DCIT, CIRCLE - 5(1), KOLKATA, KOLKATA vs. M/S. COAL INDIA LIMITED , KOLKATA

In the result, the appeals filed by the assessee in ITA Nos

ITA 622/KOL/2018[2011-12]Status: DisposedITAT Kolkata20 Jan 2026AY 2011-12
Section 115J

VI to\nthe Companies Act' is made for the limited purpose of empowering the\nassessing authority to rely upon the authentic statement of accounts of the\ncompany. While so looking into the accounts of the company, an Assessing\nOfficer under the Income-tax Act has to accept the authenticity of the\naccounts with reference to the provisions of the Companies

DCIT, CIR-5(1), , KOLKATA vs. M/S COAL INDIA LTD., KOLKATA

ITA 1696/KOL/2019[2013-14]Status: DisposedITAT Kolkata20 Jan 2026AY 2013-14
Section 115J

VI to\nthe Companies Act' is made for the limited purpose of empowering the\nassessing authority to rely upon the authentic statement of accounts of the\ncompany. While so looking into the accounts of the company, an Assessing\nOfficer under the Income-tax Act has to accept the authenticity of the\naccounts with reference to the provisions of the Companies

COAL INDIA LIMITED ,KOLKATA vs. DCIT, CIRCLE - 5(1), KOLKATA, KOLKATA

ITA 467/KOL/2018[2012-13]Status: DisposedITAT Kolkata20 Jan 2026AY 2012-13
Section 115J

VI to\nthe Companies Act' is made for the limited purpose of empowering the\nassessing authority to rely upon the authentic statement of accounts of the\ncompany. While so looking into the accounts of the company, an Assessing\nOfficer under the Income-tax Act has to accept the authenticity of the\naccounts with reference to the provisions of the Companies

M/S. COAL INDIA LIMITED ,KOLKATA vs. DCIT, CIRCLE - 5(1), KOLKATA, KOLKATA

ITA 1406/KOL/2019[2013-14]Status: DisposedITAT Kolkata20 Jan 2026AY 2013-14
Section 115J

VI to\nthe Companies Act' is made for the limited purpose of empowering the\nassessing authority to rely upon the authentic statement of accounts of the\ncompany. While so looking into the accounts of the company, an Assessing\nOfficer under the Income-tax Act has to accept the authenticity of the\naccounts with reference to the provisions of the Companies