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29 results for “transfer pricing”+ Section 25clear

Sorted by relevance

Mumbai1,599 Delhi1,415 Hyderabad356 Chennai349 Bangalore315 Ahmedabad237 Jaipur203 Chandigarh163 Kolkata149 Indore118 Pune92 Cochin87 Rajkot85 Surat65 Visakhapatnam44 Raipur39 Nagpur37 Cuttack32 Lucknow29 Amritsar25 Agra22 Jodhpur22 Dehradun21 Guwahati17 Patna6 Jabalpur6 Varanasi6 Allahabad3 Ranchi3 Panaji1

Key Topics

Section 1165 Section 12A28 Addition to Income26 Exemption15 Section 6814 Section 153A12 Section 2(15)12 Disallowance12 Section 153D9

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

25 1. The learned Assessing Officer and Transfer Pricing Officer have erred in law and on facts in making an adjustment under section

Showing 1–20 of 29 · Page 1 of 2

Section 143(3)6

Business Income6

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)

Pricing provisions have no application in the present case for comparison of profits of Dehradun and Lucknow units of the assessee. Further, there is nothing on record to show that the assessee company had specified domestic transactions with its Associate Enterprises the aggregate of which exceeded Rs.20 cr. Further, we have already noted earlier that there was reasonable explanation

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

transferred, shall be increased or decreased, as the case may be, by the amount or the aggregate of the amounts referred to in the said sub-clause relatable to such foreign operations. Explanation.—For the purposes of this sub-section, the expression— (i) "year of convergence" means the previous year within which the convergence date falls; (ii) "convergence date" means

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

25% of legal expenses as had been made in the assessment.\n4. BECAUSE the amount of expenses claimed under the above mentioned head was\nfully supported by proper bills and vouchers and the same were duly accounted for in\nthe books of account which had been subjected to twin audits and no defect or\ndiscrepancy having been found and specified

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

transferred back to the State Government under section 58 upon dissolution of the Authority and there was no restriction as to how the same would be utilized by the State Government. On perusal of the objects of the authority, he concluded that the objects within which the authority were set up may appear to be of general public utility

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 \nback to the State Government under section 58 upon dissolution of the Authority and there was \nno restriction as to how the same would be utilized by the State Government. On perusal of the \nobjects of the authority, he concluded that the objects within which the authority were set up \nmay appear to be of general public utility

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

transferred \nback to the State Government under section 58 upon dissolution of the Authority and there was \nno restriction as to how the same would be utilized by the State Government. On perusal of the \nobjects of the authority, he concluded that the objects within which the authority were set up \nmay appear to be of general public utility

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

transferred \nback to the State Government under section 58 upon dissolution of the Authority and there was \nno restriction as to how the same would be utilized by the State Government. On perusal of the \nobjects of the authority, he concluded that the objects within which the authority were set up \nmay appear to be of general public utility

DY. CIT(EXEMPTION), LUCKNOW vs. MORADABAD DEVELOPMENT AUTHORITY, MORADABAD

In the result, ITA No. 1071/Del/2020, ITA No

ITA 273/LKW/2019[2014-15]Status: DisposedITAT Lucknow31 Jan 2025AY 2014-15

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharyita Nos.273,199/Lkw/2019 A.Ys. 2014-15 & 2015-16 Dy. Commissioner Of Income Tax Vs. M/S Moradabad Development (Exemption), Lucknow Authority, Kanth Road, Moradabad Pan:Aajfm7731M (Appellant) (Respondent)

For Appellant: Ms. Shweta Mittal, C.A. & Sh. Mradul Agarwal C.AFor Respondent: Sh. Mazahar Akram, CIT DR

Section 11Section 12ASection 13Section 154Section 2(15)Section 250

section 2(15) and the various case laws on the subject, which again were outside the purview of jurisdiction under section 154 and his own powers under section 250. 23. It may not be out of place to mention at this stage, that the Hon’ble Lucknow Bench of the ITAT has dealt with this issue (of violation of section

MORADABAD DEVELOPMENT AUTHORITY,MORADABAD vs. DCIT(EXEMPTION), LUCKNOW

In the result, ITA No. 1071/Del/2020, ITA No

ITA 1072/DEL/2020[2015-16]Status: DisposedITAT Lucknow31 Jan 2025AY 2015-16

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharyita Nos.273,199/Lkw/2019 A.Ys. 2014-15 & 2015-16 Dy. Commissioner Of Income Tax Vs. M/S Moradabad Development (Exemption), Lucknow Authority, Kanth Road, Moradabad Pan:Aajfm7731M (Appellant) (Respondent)

For Appellant: Ms. Shweta Mittal, C.A. & Sh. Mradul Agarwal C.AFor Respondent: Sh. Mazahar Akram, CIT DR

Section 11Section 12ASection 13Section 154Section 2(15)Section 250

section 2(15) and the various case laws on the subject, which again were outside the purview of jurisdiction under section 154 and his own powers under section 250. 23. It may not be out of place to mention at this stage, that the Hon’ble Lucknow Bench of the ITAT has dealt with this issue (of violation of section

MORADABAD DEVELOPMENT AUTHORITY,MORADABAD vs. DY. CIT(EXEMPTION), LUCKNOW

In the result, ITA No. 1071/Del/2020, ITA No

ITA 1073/DEL/2020[2016-17]Status: DisposedITAT Lucknow31 Jan 2025AY 2016-17

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharyita Nos.273,199/Lkw/2019 A.Ys. 2014-15 & 2015-16 Dy. Commissioner Of Income Tax Vs. M/S Moradabad Development (Exemption), Lucknow Authority, Kanth Road, Moradabad Pan:Aajfm7731M (Appellant) (Respondent)

For Appellant: Ms. Shweta Mittal, C.A. & Sh. Mradul Agarwal C.AFor Respondent: Sh. Mazahar Akram, CIT DR

Section 11Section 12ASection 13Section 154Section 2(15)Section 250

section 2(15) and the various case laws on the subject, which again were outside the purview of jurisdiction under section 154 and his own powers under section 250. 23. It may not be out of place to mention at this stage, that the Hon’ble Lucknow Bench of the ITAT has dealt with this issue (of violation of section

MORADABAD DEVELOPMENT AUTHORITY,MORADABAD vs. DCIT(EXEMPTION), LUCKNOW

In the result, ITA No. 1071/Del/2020, ITA No

ITA 1071/DEL/2020[2014-15]Status: DisposedITAT Lucknow31 Jan 2025AY 2014-15

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharyita Nos.273,199/Lkw/2019 A.Ys. 2014-15 & 2015-16 Dy. Commissioner Of Income Tax Vs. M/S Moradabad Development (Exemption), Lucknow Authority, Kanth Road, Moradabad Pan:Aajfm7731M (Appellant) (Respondent)

For Appellant: Ms. Shweta Mittal, C.A. & Sh. Mradul Agarwal C.AFor Respondent: Sh. Mazahar Akram, CIT DR

Section 11Section 12ASection 13Section 154Section 2(15)Section 250

section 2(15) and the various case laws on the subject, which again were outside the purview of jurisdiction under section 154 and his own powers under section 250. 23. It may not be out of place to mention at this stage, that the Hon’ble Lucknow Bench of the ITAT has dealt with this issue (of violation of section

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

25,82,000/- being the balance left after having made payments in SBNs amounting to Rs.43,73,319/- out of the total cash receipts in SBNs, amounting to Rs.56,74,051/-. Thus, in a way, the AO has negated his own theory by permitting the benefit of allowing the deduction of payments made in SBNs, although

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

25% of legal expenses as had been made in the assessment.\n\n4. BECAUSE the amount of expenses claimed under the above mentioned head was\nfully supported by proper bills and vouchers and the same were duly accounted for in\nthe books of account which had been subjected to twin audits and no defect or\ndiscrepancy having been found

NETPLAST PVT.LTD.,KANPUR vs. ACIT CIRCLE 2(3)(1), KANPUR

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

ITA 320/LKW/2024[2017-18]Status: DisposedITAT Lucknow10 Jul 2025AY 2017-18

Section 133(6)Section 142(1)Section 14ASection 69C

transferred in her account received from M/s Netplast Pvt Ltd. Further on 11.07.2013, she\ndeposited Rs.82,00,000.00 in cash in her account, and on 17.07.2013 she got a cheque of Rs.33,00,000.00\ntransferred in her account received from M/s Netplast Pvt Ltd.\nHer bank account itself signifies that she has received Rs.83,00,000.00 on those very days

MAHESH MITTAL,LUCKNOW vs. ACIT, RANGE-5, LUCKNOW, LUCKNOW

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

ITA 73/LKW/2023[2014-15]Status: DisposedITAT Lucknow14 Aug 2025AY 2014-15

Bench: Shri Kul Bharat & Shri Anadee Nath Misshramahesh Mittal V. Acit, Range-5 1/16, Vinay Khand Gomti Income Tax Office Ashok Nagar, Lucknow-226010. Marg, Lucknow-226001. Pan:Acqpm4459B (Appellant) (Respondent) Appellant By: Shri Akshay Agarwal, Adv Respondent By: Shri Amit Singh Chauhan, Cit(Dr) O R D E R

For Appellant: Shri Akshay Agarwal, AdvFor Respondent: Shri Amit Singh Chauhan, CIT(DR)

Section 10(38)Section 68

Section 68 of the Act. 11)That, the Appellant craves leave to alter, amend, add or delete one or all the Grounds of appeals mentioned above.” Page 3 of 31 (B). In this case, assessment order dated 27.03.2023 was passed by the Assessing Officer u/s 143(3) of the Income Tax Act, 1961 (“Act”, for short) whereby the assessee

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

section 11(2), while directing the ld. AO to compute the income in the manner provided under section 11. Accordingly, additional ground number 2 does not seem to fit with the facts of the case and therefore it is also dismissed. This brings us to additional ground number 3 ie that the Ld CIT(A) has not considered whether

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

For Appellant: \nMs. Shweta Mittal, C.AFor Respondent: \nSh. G.C. Shrivastava, Special Counsel &

Section 11Section 12A

section 11, did not consider the findings of the AO with\nrespect to section 11(2), section 13(1)(d) and section 13(3). He has pointed out that\nonce the ld. CIT(A) had held that the income of the assessee should be computed in\nthe manner specified in section 11, taking into account information given in the\naudit

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

25% of legal expenses as had been made in the assessment.\n\n4. BECAUSE the amount of expenses claimed under the above mentioned head was\nfully supported by proper bills and vouchers and the same were duly accounted for in\nthe books of account which had been subjected to twin audits and no defect or\ndiscrepancy having been found

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

section 11, declined to allow the assessee the benefit of\naccumulation under section 11(2) in either assessment year because of (i) its failure\nto specify the purpose for accumulation in assessment year 2007-08 and (ii) its\nfailure to file Form No.10 before the completion before the completion of\nassessment and also to specify purpose of accumulation