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2 results for “transfer pricing”+ Section 282(1)clear

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Key Topics

Section 26314Section 153D3Section 143(3)2

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

282 (SC): 213 CTR 266 (SC)\n1. In our view at the relevant time two views were possible on the word \"profits\" in the proviso to\nSection 80HHC(3). It is true that vide the 2005 amendment the law has been clarified with\nretrospective effect by insertion of the word \"loss\" in the new proviso. We express no opinion

SHRI CHETAN SHARMA,KANPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), KANPUR

In the result, both appeals are allowed

ITA 343/LKW/2019[2014-15]Status: DisposedITAT Lucknow06 Jan 2025AY 2014-15

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

For Appellant: Shri Samrat Chandra, CA
For Respondent: Shri. Sanjeev Krishna Sharma, Addl
Section 153DSection 263

transfer certificate, copy of bank statement, copy of D-mat account, which are placed on record and are verificable.” Inspite of the above stated categorical office note recorded by Assessing Officer, the Ld. PCIT took the view that the Assessing Officer failed to make inquiries about the assessees claim for Long Term Capital Gain, and passed the aforesaid orders under