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36 results for “transfer pricing”+ Deductionclear

Sorted by relevance

Mumbai1,591Delhi1,203Chennai377Bangalore283Hyderabad270Ahmedabad211Jaipur177Kolkata149Chandigarh143Pune125Cochin117Rajkot86Indore82Surat61Visakhapatnam42Lucknow36Raipur35Cuttack34Nagpur32Jodhpur24Amritsar21Agra17Dehradun13Jabalpur8Panaji7Varanasi7Ranchi5Allahabad4Guwahati4Patna3

Key Topics

Section 1165Addition to Income31Section 12A28Section 26321Section 153C20Disallowance20Exemption15Section 2(15)12Deduction11Section 41(1)

MIRZA INTERNATIONAL LIMITED,KANPUR vs. DCIT CIRCLE 2(1)(1), KANPUR

The appeals of the assessee stand partly allowed

ITA 35/LKW/2022[2017-2018]Status: DisposedITAT Lucknow30 Jun 2025AY 2017-2018

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

For Appellant: Shri Akshay Gupta, C.AFor Respondent: Shri Sunil Kumar Rajwanshi, D.R
Section 143(3)Section 40A(7)Section 80Section 92Section 92C

deduction. It was submitted that on manufacture being completed, the stocks are transferred to another unit in Noida which was Central Warehouse for the assessee and for such transfer, the assessee regularly employs internal TNMM for the purpose of determining the Arm’s Length Price

Showing 1–20 of 36 · Page 1 of 2

10
Section 689
Section 143(3)9

SUPERHOUSE LIMITED,KANPUR vs. CIT, INTERNATIONAL TAXATION-3, DELHI, DELHI

In the result, both appeals of the assessee are allowed

ITA 356/LKW/2024[2014-15]Status: DisposedITAT Lucknow25 Feb 2026AY 2014-15

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharyita Nos. 356 & 357/Lkw/2024 A.Ys. 2014-15 & A.Ys. 2015-16 Superhouse Limited, 150 Feet Vs. The Commissioner Of Income Tax Road, Jajmau, Kanpur-208010 International Taxation-3, Delhi Pan: Aabcs9328K (Appellant) (Respondent) Assessee By: Sh. G.C. Srivastava, Adv & Sh. Kalrav Mehrotra, Adv Revenue By: Sh. R.K. Agarwal, Cit Dr Date Of Hearing: 03.12.2025 Date Of Pronouncement: 25.02.2026 O R D E R Per Nikhil Choudhary, A.M.: These Two Appeals Have Been Filed By The Assessee Against The Orders Of The Cit, (International Taxation)-3, Delhi Passed Under Section 263 Of The Act For The A.Ys. 2014-15 & 2015-16, Both Dated 29.03.2024, Wherein The Ld. Cit Has Set Aside The Earlier Orders Of The Assessing Officer For Making Of Fresh Orders In Accordance With The Directions Issued By Her. The Grounds Of Appeal Are As Under:- “1. Because, On The Facts & Circumstances Of The Case & In Law, The Ld. Cit Has Erred In Assuming Jurisdiction Under Section 263 Of The Act & In Doing So, Has Sought To Substitute His Opinion With The Order Under Section 201(1)/201(1A) Passed After Undertaking Extensive & Detailed Consideration Of The Issue By The Ito (Tds). 2. Because, On The Facts & Circumstances Of The Case & In Law, The Ld. Cit Has Erred In Assuming The Jurisdiction Under Section 263 Of The Act Without Appreciating That The Order Under Section 201(1)/201(1A) Passed By The Ito (Tds) Was Unerring & In Consonance With The Settled Principles Of Law. 3. Because, On The Facts & Circumstances Of The Case & In Law, The Impugned Order While Premised On An Illegal Assumption Of Jurisdiction, Further Suffers From Non-Application Of Mind Since The Submissions Of The Assessee Have Not Been Considered [As Illustrated Infra]. A.Ys. 2014-15 & 2015-16

For Appellant: Sh. G.C. Srivastava, Adv & Sh. KalravFor Respondent: Sh. R.K. Agarwal, CIT DR
Section 201(1)Section 263Section 90

deduct the tax at source on the commission paid as per the provisions of section 195 of the Act. 6. The ld. CIT, (International Taxation) rejected reliance upon the transfer pricing

ASTT. COMMISSIONER OF INCOME TAX, LUCKNOW vs. M/S PRAG INDUSTRIES (INDIA) PVT. LTD., LUCKNOW

In the result, appeal of Revenue and Cross Objection of assessee, both are dismissed

ITA 660/LKW/2016[2013-14]Status: DisposedITAT Lucknow11 Dec 2024AY 2013-14

Bench: Shri Kul Bharat, Videshri Anadee Nath Misshra

Section 40A(2)

deduction in relation to bad debt, it is not necessary to establish that the debt had become irrecoverable and further that it is sufficient if assessee forms such an opinion and writes off debt as irrecoverable in its account. In view of the foregoing, we are of the view that the decision of learned CIT(A) deleting the aforesaid addition

TACK EXIM PVT. LTD.,KANPUR vs. ACIT CIRCLE2(3)(1), KANPUR

The appeal of the assessee stands allowed

ITA 324/LKW/2024[2017-18]Status: DisposedITAT Lucknow29 Nov 2024AY 2017-18

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudharyassessment Year: 2017-18 Tack Exim Pvt. Limited V. Asstt. Commissioner Of 11/18-A, Pokharpur Income Tax, Jajmau, Kanpur Circle 2(3)(1), Kanpur Tan/Pan:Aadct7929D (Appellant) (Respondent) Appellant By: Shri Rakesh Garg, Advocate Respondent By: Shri Sanjeev Krishna Sharma, D.R. Date Of Hearing: 02 09 2024 Date Of Pronouncement: 29 11 2024 O R D E R

For Appellant: Shri Rakesh Garg, AdvocateFor Respondent: Shri Sanjeev Krishna Sharma, D.R
Section 115BSection 143(2)Section 143(3)Section 144Section 271ASection 68

transferring or receiving SBNs is only after the 'appointed day' which is 31.12.2016. In view of the above, it is our view that there is no violation by the assessee of any law in accepting SBNs against sales made in cash and in receiving cash from debtors. 7.3.0 Furthermore, even the CBDT had issued various Standard Operating Procedures (SOPs) instructing

U.P HOUSING & DEVELOPMENT BOARD,LUCKNOW vs. INCOME TAX OFFICER-2(3), LUCKNOW

In the result ITA Nos.532 & 533/Lkw/2014 and ITA Nos

ITA 535/LKW/2014[2008-09]Status: DisposedITAT Lucknow28 Feb 2025AY 2008-09
For Appellant: Ms. Shweta Mittal, C.AFor Respondent: Sh. G.C. Shrivastava, Special Counsel & Sh. Mazhar Akram, CIT (DR)
Section 11Section 12A

deduction of a certain sum of fund transferred to various units for the purposes of development etc., construction work. The assessee's submissions were not found to be satisfactory as no details of these sources of funds along with documentary evidences were furnished. Therefore, the ld. AO added back these amounts to the income of the assessee. In Schedule

ALLIANCE NIRMAAN LIMITED,BAREILLY vs. PCIT, BAREILLY

In the result, the appeal of the assessee is allowed

ITA 119/LKW/2022[2017-18]Status: DisposedITAT Lucknow12 Jun 2025AY 2017-18
Section 143(3)Section 263

deduction was\nallowed in full on payment basis in this year, but the same needed to be allowed in subsequent\nyears, if said payment was not allowed during the year under consideration. Likewise, provision\nfor wage arrears was also liable to be allowed, when the actual payment had been made. In this\ncase, assessee had made payment in the subsequent

RAJDHANI NAGAR SAHKARI BANK LTD,LUCKNOW vs. DY.CIT, LUCKNOW

In the result, the appeal of the assessee in ITA

ITA 114/LKW/2024[2017-18]Status: DisposedITAT Lucknow22 May 2025AY 2017-18
For Appellant: \nSh. K.R. Rastogi, C.AFor Respondent: \nSh. Sanjeev Krishna Sharma, Addl. CIT-DR
Section 36(1)(v)Section 43B

transferred to the Provident Fund Commissioner on 29.11.2016 after registering the EPF with the Provident Fund Commissioner on 05.08.2015. Accordingly, it was prayed that deduction may kindly be allowed. With regard to the denial of deduction on account of leave encashment actually paid, it was submitted that the action of the Ld. CIT(A) was incorrect because the authorities below

ACIT CIRCLE 3, LUCKNOW vs. RAJDHANI NAGAR SAHKARI BANK LTD, LUCKNOW

In the result, the appeal of the assessee in ITA

ITA 141/LKW/2024[2016-17]Status: DisposedITAT Lucknow22 May 2025AY 2016-17

Bench: Shri Kul Bharat & Before Shri Kul Bharat & Before Shri Kul Bharat & Shri Nikhil Choudharyshri Nikhil Choudharyshri Nikhil Choudharyita Nos. 112 To 114/Lkw/2024 A.Ys. 2015-16 To 2017-18 Rajdhani Nagar Sahkari Rajdhani Nagar Sahkari Vs. Dcit Bank Ltd P.K. Complex, Raja Ram Mohan P.K. Complex, Raja Ram Mohan 555Ga/86, Sardari Khera, 555Ga/86, Sardari Khera, Rai Marg, Lucknow-226001. 226001. Alambagh, Lucknow-226006 226006 Pan:Aaaar1269D (Appellant) (Respondent) (Respondent) A.Y.2016-17 Acit Circle-3 Vs. Rajdhani Nagar Sahkari Bank Rajdhani Nagar Sahkari Bank 57 Ram Tirath Marg Pratyaksh 57 Ram Tirath Marg Pratyaksh Ltd Kar Bhawan, Lucknow Kar Bhawan, Lucknow-226001 555Ga/86, Sardari Khera, 555Ga/86, Sardari Khera, Alambagh, Lucknow-226006 226006 Pan: Aaaar1269D (Appellant) (Respondent) (Respondent) Assessee By: Sh. K.R. Rastogi, C.A. Sh. Shubham Rastogi, C.A. Revenue By: Sh. Sanjeev Krishna Sharma, Addl. Addl. Cit- Dr Date Of Hearing: 28.04.2025 Date Of Pronouncement: Date Of Pronouncement: 22.05.2025 O R D E R Per Bench.: These Four Appeals Have Been Have Been Filed For The Assessment Years 2015 For The Assessment Years 2015-16, 2016- 17 & 2017-18 By The Assessee & Revenue Ssessee & Revenue Against The Respective Orders Of The Respective Orders Of The Ld. Cit(A)/Nfac, Delhi Dated 02.02.2024, 05.02.2024 & 05.02.2024 Delhi Dated 02.02.2024, 05.02.2024 & 05.02.2024. While The Delhi Dated 02.02.2024, 05.02.2024 & 05.02.2024 Assessee Is In Appeal In Assessment Years 2015 Assessee Is In Appeal In Assessment Years 2015-16, 2016-17 & 2017-18, The Revenue 18, The Revenue

For Appellant: Sh. K.R. Rastogi, C.AFor Respondent: Sh. Sanjeev Krishna Sharma, Addl
Section 36(1)(v)

transferred to the Provident Fund Commissioner on 29.11.2016 after registering the EPF with the Provident Fund Commissioner on 05.08.2015. Accordingly, it was prayed that deduction may kindly be allowed. With regard to the denial of deduction on account of leave encashment actually paid, it was submitted that the action of the Ld. CIT(A) was incorrect because the authorities below

RAJDHANI NAGAR SAHKARI BANK LTD,LUCKNOW vs. DY. CIT, LUCKNOW

In the result, the appeal of the assessee in ITA

ITA 113/LKW/2024[2016-17]Status: DisposedITAT Lucknow22 May 2025AY 2016-17
For Appellant: \nSh. K.R. Rastogi, C.AFor Respondent: \nSh. Sanjeev Krishna Sharma, Addl. CIT-
Section 36(1)(v)Section 43B

transferred to\nthe Provident Fund Commissioner on 29.11.2016 after registering the EPF with the\nProvident Fund Commissioner on 05.08.2015. Accordingly, it was prayed that\ndeduction may kindly be allowed. With regard to the denial of deduction on account\nof leave encashment actually paid, it was submitted that the action of the Ld. CIT(A)\nwas incorrect because the authorities below

RAJDHANI NAGAR SAHKARI BANK LTD,LUCKNOW vs. DY.CIT, LUCKNOW

ITA 112/LKW/2024[2015-16]Status: DisposedITAT Lucknow22 May 2025AY 2015-16
Section 36(1)(v)Section 43B

transferred to\nthe Provident Fund Commissioner on 29.11.2016 after registering the EPF with the\nProvident Fund Commissioner on 05.08.2015. Accordingly, it was prayed that\ndeduction may kindly be allowed. With regard to the denial of deduction on account\nof leave encashment actually paid, it was submitted that the action of the Ld. CIT(A)\nwas incorrect because the authorities below

INCOME TAX OFFICER-3(1), KANPUR vs. SHRI ARVIND KUMAR GUPTA, KANPUR

In the result, the appeal is held to be allowed for statistical purposes

ITA 174/LKW/2020[2015-16]Status: DisposedITAT Lucknow11 Jun 2025AY 2015-16

Bench: SH.KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: NoneFor Respondent: Sh. Sanjeev Krishna Sharma, Addl CIT (DR)
Section 143(3)Section 250Section 268A

deduction under section 10(38) for long term capital gain to the tune of Rs.59,21,368/- arising out of transfer of shares in the scrips of Kailash Auto Finance Limited. The ld. AO noted that a report had been circulated by the Directorate of Income Tax (Inv), Kolkata regarding, “bogus” LTCG arising out of trading in various penny stocks

M/S AYODHYA DEVELOPMENT AUTHORITY (FORMELY AYODHYA FAIZABAD DEVELOPMENT AUTHORITY),LUCKNOW vs. THE DY. COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW, LUCKNOW

In the result all six appeals filed by the assessee are partly allowed

ITA 145/LKW/2021[2018-2019]Status: DisposedITAT Lucknow31 Jan 2025AY 2018-2019
For Appellant: Ms. Shweta Mittal, C.A. & Sh Mradul AgarwalFor Respondent: Sh. Ghiyasuddin CIT(DR) & Sh.Mazahar Akram, CIT
Section 11Section 12ASection 2(15)Section 58

transferred the amount to the balance-sheet, which was against \nnormal accounting principles. Since, he had already denied the assessee’s claim for exemption \nunder section 11, the ld. AO decided to treat the grant of Rs.8,68,50,000/-, as the income of the \nassessee, and it was accordingly added back to the income of the assessee. Finally

M/S MODEL TANNERS (INDIA) PVT. LTD.,KANPUR vs. ASTT. COMMISSIONER OF INCOME TAX, KANPUR

In the result, ITA No. 374/LKW/2017 is partly allowed while ITA No

ITA 375/LKW/2017[2009-10]Status: DisposedITAT Lucknow30 Jan 2026AY 2009-10
For Appellant: Sh. Ashish Jaiswal, AdvFor Respondent: Sh. Puneet Kumar, CIT DR
Section 153ASection 153CSection 153DSection 801BSection 80I

price prevailing in the market and this cash was being carried by Mr. Mehtab Alam. The bank was requested to issue a certificate for the aforementioned purpose. Consequent to this search, the case of the assessee was centralized with the DCIT, Central Circle-I, Kanpur on 23.03.2012. Subsequently, it was transferred to the DCIT, Central Circle-II. Prior to this

M/S MODEL TANNERS (INDIA) PVT. LTD.,KANPUR vs. ASTT. COMMISSIONER OF INCOME TAX, KANPUR

In the result, ITA No. 374/LKW/2017 is partly allowed while ITA No

ITA 374/LKW/2017[2005-06]Status: DisposedITAT Lucknow30 Jan 2026AY 2005-06
For Appellant: Sh. Ashish Jaiswal, AdvFor Respondent: Sh. Puneet Kumar, CIT DR
Section 153ASection 153CSection 153DSection 801BSection 80I

price prevailing in the market and this cash was being carried by Mr. Mehtab Alam. The bank was requested to issue a certificate for the aforementioned purpose. Consequent to this search, the case of the assessee was centralized with the DCIT, Central Circle-I, Kanpur on 23.03.2012. Subsequently, it was transferred to the DCIT, Central Circle-II. Prior to this

NIRMAL SINGH,AYODHYA vs. ITO WARD-1,, FAIZABAD

In the result, the appeal of the assessee is allowed

ITA 83/LKW/2024[2014-15]Status: DisposedITAT Lucknow10 Oct 2024AY 2014-15

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria & Sa. No. 07/Lkw/2024 (Arising Out Of Ita. No.83/Lkw/2024 (Assessment Year: 2014-15) Nirmal Singh The Income Tax Officer, V. 15/2/16, Janki Ghat, Ayodhya- Ward-1, 224123, Faizabad (Up). Cinema Road, Faizabad- New-224001. Pan:Bdsps4165C (Appellant) (Respondent) Appellant By: Shri. Rakesh Garg, Adv Respondent By: Shri. Sanjeev Krishna Sharma, Addl. Cit(Dr) Date Of Hearing: 24 09 2024 Date Of Pronouncement: 10 10 2024 O R D E R

For Appellant: Shri. Rakesh Garg, AdvFor Respondent: Shri. Sanjeev Krishna Sharma, Addl
Section 144BSection 147Section 148Section 151Section 250Section 56(2)(vii)

transferred for a consideration less than its stamp duty value. «The appellant contended that the agreement for sale of section of property was done in 2012. Hence, Section 56(2)(vii) is nat applicable in his case. In my view, The Section 56(2)(vii) does not consider the date of the agreement but rather focuses on the amount received

RAJDHANI NAGAR SAHKARI BANK LTD,LUCKNOW vs. DY.CIT RANGE-6, LUCKNOW

In the result, both the appeals in ITA Nos

ITA 142/LKW/2024[2012-13]Status: DisposedITAT Lucknow30 Apr 2025AY 2012-13
Section 2(24)(x)Section 36(1)Section 36(1)(v)

transferred to Provident Fund Commissioners Lucknow.\n6. The addition made are highly excessive, contrary to the facts, law and principle of\nnatural justice and without providing sufficient time and opportunity to have its say\non the reasons relied upon.”\nThe facts of the case are that the assessee filed a return of income on\n29.09.2012 declaring a total income

INCOME TAX OFFICER-2(3), LUCKNOW vs. U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result ITA Nos.532 & 533/Lkw/2014 and ITA Nos

ITA 533/LKW/2014[2008-09]Status: DisposedITAT Lucknow28 Feb 2025AY 2008-09
Section 11Section 12A

transfer to have been claimed as expense by Units.\"\n3. The facts of the case are that the appellant was constituted by the\nGovernment of U.P. in terms of the provisions of section 3 of the Uttar Pradesh Awas\nEvam Vikas Parishad Adhiniyam, 1965. Section 15 in Chapter 3 of the Adhiniyam\nprovides for the functions of the Parishad, which

DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result ITA Nos.532 & 533/Lkw/2014 and ITA Nos

ITA 21/LKW/2019[2007-08]Status: DisposedITAT Lucknow28 Feb 2025AY 2007-08
Section 11Section 12A

transfer to have been claimed as expense by Units.\"\n\n3.\nThe facts of the case are that the appellant was constituted by the\nGovernment of U.P. in terms of the provisions of section 3 of the Uttar Pradesh Awas\nEvam Vikas Parishad Adhiniyam, 1965. Section 15 in Chapter 3 of the Adhiniyam\nprovides for the functions of the Parishad

DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW vs. M/S U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result ITA Nos.532 & 533/Lkw/2014 and ITA Nos

ITA 22/LKW/2019[2008-09]Status: DisposedITAT Lucknow28 Feb 2025AY 2008-09
Section 11Section 12A

transfer to have been claimed as expense by Units.\"\n\n3. The facts of the case are that the appellant was constituted by the\nGovernment of U.P. in terms of the provisions of section 3 of the Uttar Pradesh Awas\nEvam Vikas Parishad Adhiniyam, 1965. Section 15 in Chapter 3 of the Adhiniyam\nprovides for the functions of the Parishad

INCOME TAX OFFICER-2(3), LUCKNOW vs. U.P AWAS EVAM VIKAS PARISHAD, LUCKNOW

In the result ITA Nos.532 & 533/Lkw/2014 and ITA Nos

ITA 532/LKW/2014[2007-08]Status: DisposedITAT Lucknow28 Feb 2025AY 2007-08
Section 11Section 12A

transfer to have been claimed as expense by Units.\"\n\n3.\nThe facts of the case are that the appellant was constituted by the\nGovernment of U.P. in terms of the provisions of section 3 of the Uttar Pradesh Awas\nEvam Vikas Parishad Adhiniyam, 1965. Section 15 in Chapter 3 of the Adhiniyam\nprovides for the functions of the Parishad