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16 results for “transfer pricing”+ Depreciationclear

Sorted by relevance

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Key Topics

Section 26319Addition to Income14Section 1113Disallowance13Natural Justice9Section 12A8Section 41(1)8Section 143(3)6Deduction6

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)

depreciation in Dehradun unit. He has also noted that there is higher deployment of labour at Lucknow unit and has mentioned the comparative figures of corresponding expenditure and corresponding labour expenditure which is Rs.8,78,002/- for Dehradun unit and multiple times more in Lucknow unit amounting to Rs.43,46,452/-. He has also noted that the power and fuel

PRECIOUS BJUILDTECH PRIVATE LIMITED,BAREILLY vs. PCIT, , BAREILLY

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

ITA 66/LKW/2022[2017-2018]Status: DisposedITAT Lucknow30 Sept 2025AY 2017-2018

Bench: Shri Kul Bharat & Shri Nikhil Choudharyआयकर अपील सं/ Ita No.66/Lkw/2022 ननिाारण वर्ा/ Assessment Year: 2017-18 Precious Buildtech Pvt Ltd V. Pcit Harmony Apartment, Adiacent Income Tax Department, To Bedi International School, Bareilly-243001. Dental College Road, Pilibhit Bypass Road, Bareilly-243001. Pan:Aagcp1255R अपीलार्थी/(Appellant) प्रत्यर्थी/(Respondent) अपीलार्थी कक और से/Appellant By: Shri Rakesh Garg, Adv प्रत्यर्थी कक और से /Respondent By: Shri Mazhar Akram, Cit(Dr) सुनवाई कक तारीख / Date Of Hearing: 24 07 2025 घोर्णा कक तारीख/ Date Of 30 09 2025 Pronouncement: आदेश / O R D E R

Section 36(1)(v)5
Exemption5
Section 2(15)4
For Appellant: Shri Rakesh Garg, AdvFor Respondent: Shri Mazhar Akram, CIT(DR)
Section 143(3)Section 263

Transfer Pricing Officer, as the case may be,] shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal [Chief Commissioner or Chief Commissioner or Principal] Commissioner or Commissioner,— a) the order is passed without making inquiries or verification which should have been made; Page

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

depreciation claim and income from real estate business during the\nyear. On this point, categorical explanation was called from the\nassessee and the same has been submitted by him, which has been\nplaced on record.”\n3.\nVide impugned order dated 23.03.2022 of the PCIT, the assessment\norder dated 14/12/2019 was set aside to be framed denovo

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

depreciation as application of funds. \n10. The Ld. Commissioner of Income-tax (Appeals) has erred in law and on facts in passing \nassessment order which is contrary to the facts and law. \n11. The appellant craves leave to add, amend, alter or withdraw any ground of appeal or \nraise any new ground of appeal during the pendency of appeal

DCIT, RANGE-3, LUCKNOW vs. M/S. PRAYAGRAJ POWER GENERATION COMPANY LTD.,, NOIDA

In the result, ground no. 1 of appeal is dismissed and ground no

ITA 393/LKW/2020[2016-17]Status: DisposedITAT Lucknow15 Oct 2025AY 2016-17

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Section 115J

depreciation is nil; or (iv) [***] to (vi) (vii) the amount of profits of sick industrial company for the assessment year commencing on and from the assessment year relevant to the previous year in which the said company has become a sick industrial company under sub- section (1) of section 17 of the Sick Industrial Companies (Special Provisions

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

ITA 518/LKW/2018[2012-13]Status: DisposedITAT Lucknow31 Jan 2025AY 2012-13
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

depreciation as application of funds. \n10. The Ld. Commissioner of Income-tax (Appeals) has erred in law and on facts in passing \nassessment order which is contrary to the facts and law. \n11. The appellant craves leave to add, amend, alter or withdraw any ground of appeal or \nraise any new ground of appeal during the pendency of appeal

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

ITA 520/LKW/2018[2015-16]Status: DisposedITAT Lucknow31 Jan 2025AY 2015-16
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

depreciation as application of funds.\n10. The Ld. Commissioner of Income-tax (Appeals) has erred in law and on facts in passing \nassessment order which is contrary to the facts and law.\n11. The appellant craves leave to add, amend, alter or withdraw any ground of appeal or \nraise any new ground of appeal during the pendency of appeal

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

ITA 143/LKW/2021[2016-2017]Status: DisposedITAT Lucknow31 Jan 2025AY 2016-2017

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

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

depreciation as application of funds. 10. The Ld. Commissioner of Income-tax (Appeals) has erred in law and on facts in passing assessment order which is contrary to the facts and law. 11. The appellant craves leave to add, amend, alter or withdraw any ground of appeal or raise any new ground of appeal during the pendency of appeal

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

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

ACIT(E), LUCKNOW vs. M/S. BHAGWANT INSTITUTE OF TECHNOLOGY, BIJNOR

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

ITA 219/LKW/2020[2013-14]Status: DisposedITAT Lucknow31 Oct 2025AY 2013-14
For Appellant: \nShri R. K. Agarwal CIT(DR)For Respondent: \nShri Vinod Kumar, CA
Section 11Section 143(2)

price fixation' is neither the forte nor the function\nof the Court and it cannot be contended that education must be available\nfree and it must be run on a charitable basis. Apex court ruled that the\ntime is not yet ripe to hold that education must be made available on a\ncharitable basis and it is true whenever trusts

MOHD. ASFAND AKHTAR,KANPUR vs. DEPUTI COMMISSIONER OF INCOME TAX CC-2, KANPUR

In the result, the appeal of Revenue in ITA

ITA 139/LKW/2022[2018-19]Status: DisposedITAT Lucknow26 Sept 2025AY 2018-19

Bench: Shri Sudhanshu Srivastava & Shri Anadee Nath Misshraassessment Year: 2018-19 Dcit, Cc-2 V. Shri Mohammad Asfand Laxmi Niwas, 10/503, Akhtar Allenganj, Kanpur-208001. Plot No.02, Block-B, Scheme-39, Ram Rai Ki Sarai, Jajmau, Kanpur Nagar-208010. Tan/Pan: Aempa0823R (Appellant) (Respondent) Assessment Year: 2018-19 Shri Mohammad Asfand Akhtar V. Dcit, Central Circle-Ii Plot No.02, Block-B, Scheme-39, 10/503, Allenganj, Kanpur- Ram Rai Ki Sarai, Jajmau, 208001. Kanpur Nagar-208010. Tan/Pan: Aempa0823R (Appellant) (Respondent) Appellant By: Shri Ashish Jaiswal, Advocate Respondent By: Shri R. K. Agarwal, Cit(Dr) O R D E R

For Appellant: Shri Ashish Jaiswal, AdvocateFor Respondent: Shri R. K. Agarwal, CIT(DR)
Section 143(3)Section 36(1)(va)Section 37Section 41Section 41(1)Section 68Section 69C

prices remain static. It was not for the Tribunal to have guess work as to for what purposes the appellant wanted to cross-examine those dealers and what extraction the appellant wanted from them. As mentioned above, the appellant had contested the truthfulness of the statements of these two witnesses and wanted to discredit their testimony for which purpose

DY.COMMISSIONER OF INCOME TAX,CC-2,, KANPUR vs. SHRI.MOHAMMAD ASFAND AKHTAR, KANPUR

In the result, the appeal of Revenue in ITA

ITA 144/LKW/2022[2018-19]Status: DisposedITAT Lucknow26 Sept 2025AY 2018-19

Bench: Shri Sudhanshu Srivastava & Shri Anadee Nath Misshraassessment Year: 2018-19 Dcit, Cc-2 V. Shri Mohammad Asfand Laxmi Niwas, 10/503, Akhtar Allenganj, Kanpur-208001. Plot No.02, Block-B, Scheme-39, Ram Rai Ki Sarai, Jajmau, Kanpur Nagar-208010. Tan/Pan: Aempa0823R (Appellant) (Respondent) Assessment Year: 2018-19 Shri Mohammad Asfand Akhtar V. Dcit, Central Circle-Ii Plot No.02, Block-B, Scheme-39, 10/503, Allenganj, Kanpur- Ram Rai Ki Sarai, Jajmau, 208001. Kanpur Nagar-208010. Tan/Pan: Aempa0823R (Appellant) (Respondent) Appellant By: Shri Ashish Jaiswal, Advocate Respondent By: Shri R. K. Agarwal, Cit(Dr) O R D E R

For Appellant: Shri Ashish Jaiswal, AdvocateFor Respondent: Shri R. K. Agarwal, CIT(DR)
Section 143(3)Section 36(1)(va)Section 37Section 41Section 41(1)Section 68Section 69C

prices remain static. It was not for the Tribunal to have guess work as to for what purposes the appellant wanted to cross-examine those dealers and what extraction the appellant wanted from them. As mentioned above, the appellant had contested the truthfulness of the statements of these two witnesses and wanted to discredit their testimony for which purpose