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19 results for “transfer pricing”+ Section 111clear

Sorted by relevance

Delhi636Mumbai460Karnataka299Bangalore189Ahmedabad124Chennai110Jaipur89Hyderabad83Indore69Kolkata69Pune68Cochin62Calcutta50Chandigarh42Rajkot26Agra20Lucknow19Raipur18SC15Cuttack14Jodhpur12Surat11Visakhapatnam11Telangana10Nagpur9Ranchi7Rajasthan3Allahabad3Guwahati2Amritsar1Andhra Pradesh1D.K. JAIN JAGDISH SINGH KHEHAR1Dehradun1

Key Topics

Section 1156Section 12A20Section 26320Section 1516Section 2(15)16Section 143(3)15Exemption14Survey u/s 133A10Section 41(1)8

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. Kalrav Sh. R.K. Agarwal, CIT DR
Addition to Income8
Section 684
Disallowance2
For Respondent:
Section 201(1)Section 263Section 90

transfer pricing orders on the grounds that the issue before her was not, “adjustment of pricing” but on characterization of income and subsequent TDS liability. Furthermore, she noted that as per, “Agency Contract” the subsidiaries companies worked for the assessee and therefore, because the control and management of the subsidiary company was situated wholly in India, the income

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

111\ntaxmann.com 287 (SC)\nWhere High Court upheld Tribunal's order holding that AO had made detailed enquiries while\nallowing assessee's claim for deduction of business expenditure and, thus, revisional order\npassed by Commissioner was not sustainable, SLP filed against High Court's order dismissed\nIn Torrent Pharmaceuticals Ltd. v.s. DCIT(2018) 173 ITD 130 (Ahd) (Trib

ISHWAR DWELLINGS PVT. LTD,KANPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, KANPUR

In the result, the appeal of the assessee stands allowed

ITA 44/LKW/2021[2015-2016]Status: DisposedITAT Lucknow17 May 2022AY 2015-2016

Bench: Shri A. D. Jain & Shri T. S. Kapoorassessment Year:2015-16

Section 115JSection 142(1)Section 143(3)Section 154Section 2(14)Section 263

price paid is not decisive to say whether the land is agricultural or not. I.T.A. No.44/Lkw/2021 Assessment Year:2015-16 14 6.7 We may refer to a judgment of the Hon'ble Madras High Court in the case of CWT vs. E. Udayakumar (2006) 284 ITR 511 (Mad) where the Hon'ble Madras High Court has referred to the decision

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

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

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Revenue byFor Respondent: Date of hearing
Section 11Section 12A

transfer and registration of property in their names and since they also had to pay premium towards price appreciation of the property, betterment charges for value addition to the property, interest on differed or delayed payments, thus what was emerging was that the activity of the assessee was purely that of a commercial organization. Therefore, the ld. AO held that

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

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

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Revenue byFor Respondent: Date of hearing
Section 11Section 12A

transfer and registration of property in their names and since they also had to pay premium towards price appreciation of the property, betterment charges for value addition to the property, interest on differed or delayed payments, thus what was emerging was that the activity of the assessee was purely that of a commercial organization. Therefore, the ld. AO held that

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

Accordingly all four additional grounds filed by the revenue in Appeal numbers 532 & 533 of 2014, stand dismissed

ITA 535/LKW/2014[2008-09]Status: DisposedITAT Lucknow28 Feb 2025AY 2008-09

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Ms. Shweta Mittal, C.AFor Respondent: Sh. G.C. Shrivastava, Special Counsel & Sh. Mazhar Akram, CIT (DR)
Section 11Section 12A

transfer and registration of property in their names and since they also had to pay premium towards price appreciation of the property, betterment charges for value addition to the property, interest on differed or delayed payments, thus what was emerging was that the activity of the assessee was purely that of a commercial organization. Therefore, the ld. AO held that

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

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

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Revenue byFor Respondent: Date of hearing
Section 11Section 12A

transfer and registration of property in their names and since they also had to pay premium towards price appreciation of the property, betterment charges for value addition to the property, interest on differed or delayed payments, thus what was emerging was that the activity of the assessee was purely that of a commercial organization. Therefore, the ld. AO held that

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

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

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Revenue byFor Respondent: Date of hearing
Section 11Section 12A

transfer and registration of property in their names and since they also had to pay premium towards price appreciation of the property, betterment charges for value addition to the property, interest on differed or delayed payments, thus what was emerging was that the activity of the assessee was purely that of a commercial organization. Therefore, the ld. AO held that

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

ITA 534/LKW/2014[2007-08]Status: DisposedITAT Lucknow28 Feb 2025AY 2007-08

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Ms. Shweta Mittal, C.AFor Respondent: Sh. G.C. Shrivastava, Special Counsel &
Section 11Section 12A

transfer and registration of property in their names and since they also had to pay premium towards price appreciation of the property, betterment charges for value addition to the property, interest on differed or delayed payments, thus what was emerging was that the activity of the assessee was purely that of a commercial organization. Therefore, the ld. AO held that

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

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 630/LKW/2016[2009-10]Status: DisposedITAT Lucknow08 Jun 2022AY 2009-10

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12ASection 143(3)Section 15Section 2(15)

section 12AA of the Act, which would be very much indifference to the intention of the legislature. In fact, the assessee authority is working on commercial pattern like a big Page 47 of 242 (UP AWAS EVAM VIKAS PARISHAD) businessman. Even otherwise, if some plots are reserved for economically weaker sections of the society, firstly, there is no parameter that

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

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 210/LKW/2017[2013-14]Status: DisposedITAT Lucknow08 Jun 2022AY 2013-14

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12ASection 143(3)Section 15Section 2(15)

section 12AA of the Act, which would be very much indifference to the intention of the legislature. In fact, the assessee authority is working on commercial pattern like a big Page 47 of 242 (UP AWAS EVAM VIKAS PARISHAD) businessman. Even otherwise, if some plots are reserved for economically weaker sections of the society, firstly, there is no parameter that

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

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 164/LKW/2017[2011-12]Status: DisposedITAT Lucknow08 Jun 2022AY 2011-12

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12ASection 143(3)Section 15Section 2(15)

section 12AA of the Act, which would be very much indifference to the intention of the legislature. In fact, the assessee authority is working on commercial pattern like a big Page 47 of 242 (UP AWAS EVAM VIKAS PARISHAD) businessman. Even otherwise, if some plots are reserved for economically weaker sections of the society, firstly, there is no parameter that

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

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 631/LKW/2016[2010-11]Status: DisposedITAT Lucknow08 Jun 2022AY 2010-11

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12ASection 143(3)Section 15Section 2(15)

section 12AA of the Act, which would be very much indifference to the intention of the legislature. In fact, the assessee authority is working on commercial pattern like a big Page 47 of 242 (UP AWAS EVAM VIKAS PARISHAD) businessman. Even otherwise, if some plots are reserved for economically weaker sections of the society, firstly, there is no parameter that

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

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 165/LKW/2017[2012-13]Status: DisposedITAT Lucknow08 Jun 2022AY 2012-13

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12ASection 143(3)Section 15Section 2(15)

section 12AA of the Act, which would be very much indifference to the intention of the legislature. In fact, the assessee authority is working on commercial pattern like a big Page 47 of 242 (UP AWAS EVAM VIKAS PARISHAD) businessman. Even otherwise, if some plots are reserved for economically weaker sections of the society, firstly, there is no parameter that

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

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 211/LKW/2017[2014-15]Status: DisposedITAT Lucknow08 Jun 2022AY 2014-15

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12ASection 143(3)Section 15Section 2(15)

section 12AA of the Act, which would be very much indifference to the intention of the legislature. In fact, the assessee authority is working on commercial pattern like a big Page 47 of 242 (UP AWAS EVAM VIKAS PARISHAD) businessman. Even otherwise, if some plots are reserved for economically weaker sections of the society, firstly, there is no parameter that

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

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 24/LKW/2017[2010-11]Status: DisposedITAT Lucknow08 Jun 2022AY 2010-11

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12ASection 143(3)Section 15Section 2(15)

section 12AA of the Act, which would be very much indifference to the intention of the legislature. In fact, the assessee authority is working on commercial pattern like a big Page 47 of 242 (UP AWAS EVAM VIKAS PARISHAD) businessman. Even otherwise, if some plots are reserved for economically weaker sections of the society, firstly, there is no parameter that

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

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 23/LKW/2017[2009-10]Status: DisposedITAT Lucknow08 Jun 2022AY 2009-10

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12ASection 143(3)Section 15Section 2(15)

section 12AA of the Act, which would be very much indifference to the intention of the legislature. In fact, the assessee authority is working on commercial pattern like a big Page 47 of 242 (UP AWAS EVAM VIKAS PARISHAD) businessman. Even otherwise, if some plots are reserved for economically weaker sections of the society, firstly, there is no parameter that

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

section 27 of the General Clauses Act, 1897 which is mentioned as under: "Meaning of service by post": Where any Central Act or Regulation made after the commencement of this Act authorizes or requires any document to be served by post, whether the expression serve or either of the expressions give or send or any other expression is used, then

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

section 27 of the General Clauses Act, 1897 which is mentioned as under: "Meaning of service by post": Where any Central Act or Regulation made after the commencement of this Act authorizes or requires any document to be served by post, whether the expression serve or either of the expressions give or send or any other expression is used, then