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33 results for “transfer pricing”+ Section 92clear

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Key Topics

Section 1138 Addition to Income24 Section 69C19 Section 2(15)18 Section 1516 Section 153A12 Section 12A12 Section 143(3)11 Exemption10

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

Transfer Pricing Officer have erred in law and on facts in making an adjustment under section 92 CA of the Act of Rs.3

Showing 1–20 of 33 · Page 1 of 2

Survey u/s 133A10

M/S. SAHARA CITY HOMES,BAREILLY vs. INCOME TAX OFFICER - 3(4), RANGE- 3, LUCKNOW

In the result, the appeals of the assessees are partly allowed

ITA 24/LKW/2019[2012-13]Status: DisposedITAT Lucknow31 Jan 2022AY 2012-13

Bench: Shri. A. D. Jain & Shri T. S. Kapoorassessment Year: 2012-13 M/S Sahara City Homes – Bareilly V. Ito-3(4) 2, Sahara India Centre Range 3 Kapoorthala Complex Lucknow Aliganj, Lucknow Tan/Pan:Abzfs2472C (Appellant) (Respondent) Assessment Year: 2012-13 M/S Sahara City Homes – Amritsar V. Ito-3(4) 2, Sahara India Centre Lucknow Tan/Pan:Abzfs4654E (Appellant) (Respondent) Assessment Year: 2012-13 M/S Sahara City Homes – Kanpur(I) V. Acit 2, Sahara India Centre Range 3 Kapoorthala Complex Lucknow Aliganj, Lucknow Tan/Pan:Abzfs2468Q (Appellant) (Respondent) Assessment Year: 2012-13 M/S Sahara City Homes – Guwahati V. Acit 2, Sahara India Centre Range 3 Kapoorthala Complex Lucknow Aliganj, Lucknow Tan/Pan:Abzfs2462E (Appellant) (Respondent)

92,350/- (Ground No.4), under section 69C of the Act, on account of opening balance of work-in-progress brought forward from the earlier year. 29. Ground No.5 challenge the ld. CIT(A)’s direction to the Assessing Officer to issue, on a protective basis, a notice under section 148 of the Act, for Assessment Year

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

ITA 145/LKW/2021[2018-2019]Status: DisposedITAT Lucknow31 Jan 2025AY 2018-2019

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

92,10,505/- being the balance in 'infrastructure development fund account'. Ld. CIT(A) failed to appreciate that the amount in the above statutory fund are specifically received by virtue of Government Order dt. 15.01.1998 and are meant for utilization in the development activities exclusively. Ld CIT(A) further failed to appreciate that the unutilized left over amount

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

92,10,505/- being the balance in 'infrastructure development fund account'. Ld. CIT(A) failed to appreciate that the amount in the above statutory fund are specifically received by virtue of Government Order dt. 15.01.1998 and are meant for utilization in the development activities exclusively. Ld CIT(A) further failed to appreciate that the unutilized left over amount

M/S. SAHARA CITY HOMES,KANPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, RANGE- 3, LUCKNOW

ITA 26/LKW/2019[2012-13]Status: DisposedITAT Lucknow31 Jan 2022AY 2012-13

For Appellant: Shri Vijay Mehta, C.AFor Respondent: Shri Sushil Madhuk, CIT (DR) (on 4.2.2020 and 5.2.2020) & Smt

transferred within a period of one year and the price thereof was to be determined mutually. Further, the valuation of the WIP is to be at the instance of the second party, who has been given the right to do so, if required. The valuation is not mandatory and, hence, the conclusion of the CIT(A) is not only irrelevant

M/S. SAHARA CITY HOMES,AMRITSAR vs. INCOME TAX OFFICER- 3(4), LUCKNOW

ITA 25/LKW/2019[2012-13]Status: DisposedITAT Lucknow31 Jan 2022AY 2012-13

For Appellant: Shri Vijay Mehta, C.AFor Respondent: Shri Sushil Madhuk, CIT (DR) (on 4.2.2020 and 5.2.2020) & Smt

transferred within a period of one year and the price thereof was to be determined mutually. Further, the valuation of the WIP is to be at the instance of the second party, who has been given the right to do so, if required. The valuation is not mandatory and, hence, the conclusion of the CIT(A) is not only irrelevant

M/S. SAHARA CITY HOMES,GUWAHATI vs. ASSISTANT COMMISSIONER OF INCOME TAX, RANGE- 3, LUCKNOW

ITA 27/LKW/2019[2012-13]Status: DisposedITAT Lucknow31 Jan 2022AY 2012-13

For Appellant: Shri Vijay Mehta, C.AFor Respondent: Shri Sushil Madhuk, CIT (DR) (on 4.2.2020 and 5.2.2020) & Smt

transferred within a period of one year and the price thereof was to be determined mutually. Further, the valuation of the WIP is to be at the instance of the second party, who has been given the right to do so, if required. The valuation is not mandatory and, hence, the conclusion of the CIT(A) is not only irrelevant

M/S. SAHARA CITY HOMES,CHENNAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, RANGE- 3, LUCKNOW

ITA 29/LKW/2019[2012-13]Status: DisposedITAT Lucknow31 Jan 2022AY 2012-13

For Appellant: Shri Vijay Mehta, C.AFor Respondent: Shri Sushil Madhuk, CIT (DR) (on 4.2.2020 and 5.2.2020) & Smt

transferred within a period of one year and the price thereof was to be determined mutually. Further, the valuation of the WIP is to be at the instance of the second party, who has been given the right to do so, if required. The valuation is not mandatory and, hence, the conclusion of the CIT(A) is not only irrelevant

M/S. SAHARA CITY HOMES,JAMNAGAR vs. INCOME TAX OFFICER -3(4), LUCKNOW

ITA 37/LKW/2019[2012-13]Status: DisposedITAT Lucknow31 Jan 2022AY 2012-13

For Appellant: Shri Vijay Mehta, C.AFor Respondent: Shri Sushil Madhuk, CIT (DR) (on 4.2.2020 and 5.2.2020) & Smt

transferred within a period of one year and the price thereof was to be determined mutually. Further, the valuation of the WIP is to be at the instance of the second party, who has been given the right to do so, if required. The valuation is not mandatory and, hence, the conclusion of the CIT(A) is not only irrelevant

M/S. SAHARA CITY HOMES,VADODARA vs. INCOME TAX OFFICER- 3(4), RANGE-3, LUCKNOW

ITA 33/LKW/2019[2012-13]Status: DisposedITAT Lucknow31 Jan 2022AY 2012-13

For Appellant: Shri Vijay Mehta, C.AFor Respondent: Shri Sushil Madhuk, CIT (DR) (on 4.2.2020 and 5.2.2020) & Smt

transferred within a period of one year and the price thereof was to be determined mutually. Further, the valuation of the WIP is to be at the instance of the second party, who has been given the right to do so, if required. The valuation is not mandatory and, hence, the conclusion of the CIT(A) is not only irrelevant

M/S. SAHARA CITY HOMES,KURUKSHETRA vs. INCOME TAX OFFICER- 3(4), LUCKNOW

ITA 30/LKW/2019[2012-13]Status: DisposedITAT Lucknow31 Jan 2022AY 2012-13

For Appellant: Shri Vijay Mehta, C.AFor Respondent: Shri Sushil Madhuk, CIT (DR) (on 4.2.2020 and 5.2.2020) & Smt

transferred within a period of one year and the price thereof was to be determined mutually. Further, the valuation of the WIP is to be at the instance of the second party, who has been given the right to do so, if required. The valuation is not mandatory and, hence, the conclusion of the CIT(A) is not only irrelevant

M/S. SAHARA CITY HOMES,RAJKOT vs. INCOME TAX OFFICER- 34), RANGE-3, LUCKNOW

ITA 38/LKW/2019[2012-13]Status: DisposedITAT Lucknow31 Jan 2022AY 2012-13

For Appellant: Shri Vijay Mehta, C.AFor Respondent: Shri Sushil Madhuk, CIT (DR) (on 4.2.2020 and 5.2.2020) & Smt

transferred within a period of one year and the price thereof was to be determined mutually. Further, the valuation of the WIP is to be at the instance of the second party, who has been given the right to do so, if required. The valuation is not mandatory and, hence, the conclusion of the CIT(A) is not only irrelevant

M/S. SAHARA CITY HOMES,AMBALA vs. INCOME TAX OFFICER -3(4), RANGE-3, LUCKNOW

ITA 34/LKW/2019[2012-13]Status: DisposedITAT Lucknow31 Jan 2022AY 2012-13

For Appellant: Shri Vijay Mehta, C.AFor Respondent: Shri Sushil Madhuk, CIT (DR) (on 4.2.2020 and 5.2.2020) & Smt

transferred within a period of one year and the price thereof was to be determined mutually. Further, the valuation of the WIP is to be at the instance of the second party, who has been given the right to do so, if required. The valuation is not mandatory and, hence, the conclusion of the CIT(A) is not only irrelevant

M/S. SAHARA CITY HOMES,MORADABAD vs. INCOME TAX OFFICER- 3(4), RANGE-3, LUCKNOW

ITA 31/LKW/2019[2012-13]Status: DisposedITAT Lucknow31 Jan 2022AY 2012-13

For Appellant: Shri Vijay Mehta, C.AFor Respondent: Shri Sushil Madhuk, CIT (DR) (on 4.2.2020 and 5.2.2020) & Smt

transferred within a period of one year and the price thereof was to be determined mutually. Further, the valuation of the WIP is to be at the instance of the second party, who has been given the right to do so, if required. The valuation is not mandatory and, hence, the conclusion of the CIT(A) is not only irrelevant

M/S. SAHARA CITY HOMES,ANAND vs. INCOME TAX OFFICER- 3(4), RANGE-3, LUCKNOW

ITA 39/LKW/2019[2012-13]Status: DisposedITAT Lucknow31 Jan 2022AY 2012-13

For Appellant: Shri Vijay Mehta, C.AFor Respondent: Shri Sushil Madhuk, CIT (DR) (on 4.2.2020 and 5.2.2020) & Smt

transferred within a period of one year and the price thereof was to be determined mutually. Further, the valuation of the WIP is to be at the instance of the second party, who has been given the right to do so, if required. The valuation is not mandatory and, hence, the conclusion of the CIT(A) is not only irrelevant

M/S. SAHARA CITY HOMES,MUZAFFAR NAGAR vs. INCOME TAX OFFICER - 3(4), RANGE- 3, LUCKNOW

ITA 35/LKW/2019[2012-13]Status: DisposedITAT Lucknow31 Jan 2022AY 2012-13

For Appellant: Shri Vijay Mehta, C.AFor Respondent: Shri Sushil Madhuk, CIT (DR) (on 4.2.2020 and 5.2.2020) & Smt

transferred within a period of one year and the price thereof was to be determined mutually. Further, the valuation of the WIP is to be at the instance of the second party, who has been given the right to do so, if required. The valuation is not mandatory and, hence, the conclusion of the CIT(A) is not only irrelevant

M/S. SAHARA CITY HOMES,ALIGARH vs. INCOME TAX OFFICER - 3(4), RANGE- 3, LUCKNOW

ITA 32/LKW/2019[2012-13]Status: DisposedITAT Lucknow31 Jan 2022AY 2012-13

For Appellant: Shri Vijay Mehta, C.AFor Respondent: Shri Sushil Madhuk, CIT (DR) (on 4.2.2020 and 5.2.2020) & Smt

transferred within a period of one year and the price thereof was to be determined mutually. Further, the valuation of the WIP is to be at the instance of the second party, who has been given the right to do so, if required. The valuation is not mandatory and, hence, the conclusion of the CIT(A) is not only irrelevant

M/S. SAHARA CITY HOMES,DEVAS vs. INCOME TAX OFFICER- 3(4), RANGE-3, LUCKNOW

ITA 28/LKW/2019[2012-13]Status: DisposedITAT Lucknow31 Jan 2022AY 2012-13

For Appellant: Shri Vijay Mehta, C.AFor Respondent: Shri Sushil Madhuk, CIT (DR) (on 4.2.2020 and 5.2.2020) & Smt

transferred within a period of one year and the price thereof was to be determined mutually. Further, the valuation of the WIP is to be at the instance of the second party, who has been given the right to do so, if required. The valuation is not mandatory and, hence, the conclusion of the CIT(A) is not only irrelevant

M/S. SAHARA CITY HOMES,KARNAL vs. INCOME TAX OFFICER -3(4), RANGE-3, LUCKNOW

ITA 36/LKW/2019[2012-13]Status: DisposedITAT Lucknow31 Jan 2022AY 2012-13

For Appellant: Shri Vijay Mehta, C.AFor Respondent: Shri Sushil Madhuk, CIT (DR) (on 4.2.2020 and 5.2.2020) & Smt

transferred within a period of one year and the price thereof was to be determined mutually. Further, the valuation of the WIP is to be at the instance of the second party, who has been given the right to do so, if required. The valuation is not mandatory and, hence, the conclusion of the CIT(A) is not only irrelevant

VIKAS JAIN,KANPUR vs. ACIT-CC 2(1)(1), KANPUR

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

ITA 434/LKW/2024[2015-16]Status: DisposedITAT Lucknow31 Dec 2025AY 2015-16

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2015-16 Vikas Jain, Vs. The Acit, H-2/1, Kidwai Nagar, Kanpur- Circle 2(1)(1), Kanpur 208001 208006 Pan: Abqpj8049R (Appellant) (Respondent) Assessee By: Sh. Rakesh Garg, Adv Revenue By: Sh. Amit Kumar, Dr Date Of Hearing: 07.10.2025 Date Of Pronouncement: 31.12.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A), Nfac On 17.05.2024 Wherein The Ld. Cit(A) Has Dismissed The Appeal Of The Assessee Against The Order Passed By The Ld. Assessing Officer Under Section 147 R.W.S. 143(3) For The A.Y. 2015-16 On 27.12.2018. The Grounds Of Appeal Are As Under:- “01. Because There Being No Reason To Believe, Far From There Being Any Material To Form Reasons To Believe, The Proceedings Initiated Right From Issue Of Notice U/S. 148 & The Re-Assessment Framed Thereof Are All Without Jurisdiction Bad In Law, The Order Passed Be Quashed. 02. Because The So-Called Reasons Having Been Recorded Applying Explanation 2(A) To Section 147, Of The Act Which Not Being Applicable, The Very Reason To Believe Being Contrary To The Mandate Of The Section, The Proceedings- Initiated U/S 148, The Reassessment Framed Are All Contrary To The Provisions Of Law, Be Quashed. 03. Because The Approval Given By The Competent Authority U/S 151, Being Mechanical In Nature Without Verification Of Facts, The Notice Issued U/S 148 & The Reassessment Framed Thereafter Be Quashed.

For Appellant: Sh. Rakesh Garg, AdvFor Respondent: Sh. Amit Kumar, DR

Section 143(1)Section 147Section 148Section 151Section 156Section 48Section 50C

transfer of an asset. Accordingly, applying the provisions of section 50C, he held reasons to believe that assessee’s income chargeable to tax of Rs. 1,10,72,650/- had escaped assessment during the assessment year 2015-16 by virtue of the proviso of Explanation 2(a) of section 147. 3. In response to the said notice, the assessee filed