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45 results for “transfer pricing”+ Set Off of Lossesclear

Sorted by relevance

Mumbai3,045Delhi2,921Bangalore1,258Chennai636Kolkata606Ahmedabad509Pune472Karnataka362Jaipur303Hyderabad287Chandigarh185Indore170Cochin150Rajkot90Visakhapatnam87Surat83SC50Calcutta47Lucknow45Nagpur42Raipur41Telangana40Cuttack37Guwahati29Jodhpur28Dehradun23Amritsar20Agra12Panaji10Varanasi10Ranchi8Jabalpur7Kerala4A.K. SIKRI ROHINTON FALI NARIMAN4Allahabad4Orissa4Rajasthan2T.S. THAKUR ROHINTON FALI NARIMAN1Punjab & Haryana1Andhra Pradesh1Patna1

Key Topics

Section 1171Section 2(15)49Section 143(3)36Section 26335Addition to Income30Section 12A28Exemption21Disallowance19Section 1516

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

Showing 1–20 of 45 · Page 1 of 3

Natural Justice15
Section 1214
Section 153A12
For Respondent:
Section 201(1)Section 263Section 90

Transfer Pricing Officer (TPO) in which the TPO had examined the payment to foreign wholly owned subsidiaries and accepted that the nature of the transactions with the foreign wholly owned subsidiaries was “Commission” and not fees for technical services. The ld. AR submitted that the income of the foreign subsidiary accrues and arose abroad. He referred to the decisions

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)

loss account and the I.T.A. No.660/Lkw/2016 C.O.No.01/Lkw/2017 8 amounts written off were in the nature of bad debts. Accordingly, he deleted the addition. At the time of hearing before us, learned CIT (D.R.) placed reliance on the order of the Assessing Officer whereas learned A.R. for the assessee supported the order of learned CIT(A). We have heard both

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

set aside as provision for diminution in the value of any asset, (j) the amount standing in revaluation reserve relating to revalued asset on the retirement or disposal of such asset, (k) the amount of gain on transfer of units referred to in clause (xvii) of section 47 computed by taking into account the cost of the shares exchanged with

LUCKNOW DEVELOPMENT AUTHORITY ,LUCKNOW vs. DCIT (E), LUCKNOW

In the result, all the appeals of the assessee are partly allowed

ITA 665/LKW/2019[2012-13]Status: DisposedITAT Lucknow05 Apr 2022AY 2012-13

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

Section 11Section 12Section 13(1)(c)Section 13(3)Section 143(3)Section 147Section 154Section 2(15)Section 40

losses however, he rejected the other issues. The assessee preferred separate appeals before the learned CIT(A) against all these three assessment orders. The learned CIT(A), finding the issues common in all these assessment years, passed a consolidated order. Against the consolidated order of learned CIT(A), the assessee filed separate appeals before the Tribunal. The grounds of appeal

LUCKNOW DEVELOPMENT AUTHORITY ,LUCKNOW vs. DCIT (E), LUCKNOW

In the result, all the appeals of the assessee are partly allowed

ITA 656/LKW/2019[2012-13]Status: DisposedITAT Lucknow05 Apr 2022AY 2012-13

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

Section 11Section 12Section 13(1)(c)Section 13(3)Section 143(3)Section 147Section 154Section 2(15)Section 40

losses however, he rejected the other issues. The assessee preferred separate appeals before the learned CIT(A) against all these three assessment orders. The learned CIT(A), finding the issues common in all these assessment years, passed a consolidated order. Against the consolidated order of learned CIT(A), the assessee filed separate appeals before the Tribunal. The grounds of appeal

LUCKNOW DEVELOPMENT AUTHORITY ,LUCKNOW vs. DCIT (E), LUCKNOW

In the result, all the appeals of the assessee are partly allowed

ITA 666/LKW/2019[2012-13]Status: DisposedITAT Lucknow05 Apr 2022AY 2012-13

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

Section 11Section 12Section 13(1)(c)Section 13(3)Section 143(3)Section 147Section 154Section 2(15)Section 40

losses however, he rejected the other issues. The assessee preferred separate appeals before the learned CIT(A) against all these three assessment orders. The learned CIT(A), finding the issues common in all these assessment years, passed a consolidated order. Against the consolidated order of learned CIT(A), the assessee filed separate appeals before the Tribunal. The grounds of appeal

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

For Appellant: Shri Rakesh Garg, AdvFor Respondent: Shri Mazhar Akram, CIT(DR)
Section 143(3)Section 263

Loss account, copy of bank accounts and other documents as directed by the Assessing Authority. It was noted by the Assessing Authority that although, the case was selected for complete scrutiny but it was selected to examine mainly the issues i.e. (i) Real estate business with high closing stock and (ii) Higher turnover reported in Service Tax Return as compared

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

transferring or receiving SBNs is only after the 'appointed day' which is 31.12.2016. In view of the above, it is our view that there is no violation by the assessee of any law in accepting SBNs against sales made in cash and in receiving cash from debtors. 7.3.0 Furthermore, even the CBDT had issued various Standard Operating Procedures (SOPs) instructing

INCOME TAX OFFICER-3(4), KANPUR vs. SHRI SANTOSH KUMAR AGARWAL, KANPUR

In the result, the appeal of the Revenue is dismissed

ITA 153/LKW/2020[2014-15]Status: DisposedITAT Lucknow17 Feb 2022AY 2014-15

Bench: Shri T. S. Kapoor

Section 10(38)Section 143(3)Section 69A

price can avail bogus Short Term Capital Loss. On December 2013 script was trading at Rs. 938.72 which fallen to Rs. 140 in mid of March 2014 there by booking STCL. AO on the basis of the above unrelated details mentioned in the assessment order held that since the shares in which the appellant has done trading

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

price or all\nsignificant risks and rewards of ownership have been transferred to the buyer and the seller\nretains no effective control of the goods transferred to a degree usually associated with\nownership; and\n(ii) no significant uncertainty exists regarding the amount of the consideration that will be\nderived from the sale of goods. Further In a transaction involving

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

In the result, the appeals of the assessee are partly allowed whereas the Cross Objections of the Revenue are partly allowed for statistical purposes

ITA 165/LKW/2019[2015-16]Status: DisposedITAT Lucknow10 Jun 2022AY 2015-16

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

Section 11Section 12Section 12ASection 13(8)Section 2(15)

set up by UP State Government and which is engaged in industrial development activity in the Greater Noida, has been held to be engaged in non commercial activities vide order dated 26/02/2018 by Hon'ble Delhi High Court and Hon'ble Supreme Court has dismissed the SLP filed by the Revenue vide order dated 25/11/2019. We further find that CBDT

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

In the result, the appeals of the assessee are partly allowed whereas the Cross Objections of the Revenue are partly allowed for statistical purposes

ITA 701/LKW/2019[2017-18]Status: DisposedITAT Lucknow10 Jun 2022AY 2017-18

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

Section 11Section 12Section 12ASection 13(8)Section 2(15)

set up by UP State Government and which is engaged in industrial development activity in the Greater Noida, has been held to be engaged in non commercial activities vide order dated 26/02/2018 by Hon'ble Delhi High Court and Hon'ble Supreme Court has dismissed the SLP filed by the Revenue vide order dated 25/11/2019. We further find that CBDT

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

In the result, the appeals of the assessee are partly allowed whereas the Cross Objections of the Revenue are partly allowed for statistical purposes

ITA 166/LKW/2019[2016-17]Status: DisposedITAT Lucknow10 Jun 2022AY 2016-17

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

Section 11Section 12Section 12ASection 13(8)Section 2(15)

set up by UP State Government and which is engaged in industrial development activity in the Greater Noida, has been held to be engaged in non commercial activities vide order dated 26/02/2018 by Hon'ble Delhi High Court and Hon'ble Supreme Court has dismissed the SLP filed by the Revenue vide order dated 25/11/2019. We further find that CBDT

LUCKNOW EVELOPMENT AUTHORITY,LUCKNOW vs. I.T.O., LUCKNOW

In the result, all the appeals are partly allowed

ITA 164/LKW/2019[2015-16]Status: DisposedITAT Lucknow10 Mar 2022AY 2015-16

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

Section 11Section 11rSection 12Section 12ASection 13(1)(c)Section 13(3)Section 143(3)Section 147Section 148Section 2(15)

loss account as this amount has to be spent for the purposes of projects as specified by a committee framed by State Government and authorities below, while denying exemption u/s 11 have disallowed this amount also which is not in accordance with law and have further made certain disallowances, which is not in accordance with law and which needs

LUCKNOW DEVELOPMENT AUTHORITY,LUCKNOW vs. ASSISTANT COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW

In the result, all the appeals are partly allowed

ITA 163/LKW/2019[2014-15]Status: DisposedITAT Lucknow10 Mar 2022AY 2014-15

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

Section 11Section 11rSection 12Section 12ASection 13(1)(c)Section 13(3)Section 143(3)Section 147Section 148Section 2(15)

loss account as this amount has to be spent for the purposes of projects as specified by a committee framed by State Government and authorities below, while denying exemption u/s 11 have disallowed this amount also which is not in accordance with law and have further made certain disallowances, which is not in accordance with law and which needs

LUCKNOW DEVELOPMENT AUTHORITY ,LUCKNOW vs. ACIT (E), LUCKNOW

In the result, all the appeals are partly allowed

ITA 186/LKW/2019[2013-14]Status: DisposedITAT Lucknow10 Mar 2022AY 2013-14

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

Section 11Section 11rSection 12Section 12ASection 13(1)(c)Section 13(3)Section 143(3)Section 147Section 148Section 2(15)

loss account as this amount has to be spent for the purposes of projects as specified by a committee framed by State Government and authorities below, while denying exemption u/s 11 have disallowed this amount also which is not in accordance with law and have further made certain disallowances, which is not in accordance with law and which needs

LUCKNOW DEVELOPMENT AUTHORITY ,LUCKNOW vs. DCIT (E), LUCKNOW

In the result, all the appeals are partly allowed

ITA 439/LKW/2019[2016-17]Status: DisposedITAT Lucknow10 Mar 2022AY 2016-17

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

Section 11Section 11rSection 12Section 12ASection 13(1)(c)Section 13(3)Section 143(3)Section 147Section 148Section 2(15)

loss account as this amount has to be spent for the purposes of projects as specified by a committee framed by State Government and authorities below, while denying exemption u/s 11 have disallowed this amount also which is not in accordance with law and have further made certain disallowances, which is not in accordance with law and which needs

LUCKNOW DEVELOPMENT AUTHORITY ,LUCKNOW vs. ACIT (E), LUCKNOW

In the result, all the appeals are partly allowed

ITA 185/LKW/2019[2013-14]Status: DisposedITAT Lucknow10 Mar 2022AY 2013-14

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

Section 11Section 11rSection 12Section 12ASection 13(1)(c)Section 13(3)Section 143(3)Section 147Section 148Section 2(15)

loss account as this amount has to be spent for the purposes of projects as specified by a committee framed by State Government and authorities below, while denying exemption u/s 11 have disallowed this amount also which is not in accordance with law and have further made certain disallowances, which is not in accordance with law and which needs

TINICH SAHKARI GANNA SAMITI LIMITED,BASTII vs. ITO, BASTI

ITA 295/LKW/2023[2015-16]Status: DisposedITAT Lucknow18 Sept 2025AY 2015-16

Bench: Shri. Sudhanshu Srivastava

For Appellant: None (Written submission)For Respondent: Shri Sanjeev Krishna Sharma and Shri Amit Kumar, D.Rs
Section 143(3)Section 244ASection 271(1)(c)Section 28Section 80PSection 80P(2)(a)

price to its member cane growers by mills. c. Marketing of the sugar cane, an agricultural produce, grown by the appellant's members. d. To provide seeds, fertilizers pesticides, agricultural equipments to members. e. To provide credits to the members. f. To arrange funds and finance for activities of the society. (Note: a copy of relevant part of the said

TINICH SAHKARI GANNA SAMITI LIMITED,BASTI vs. ITO, , BASTI

ITA 294/LKW/2023[2014-15]Status: DisposedITAT Lucknow18 Sept 2025AY 2014-15

Bench: Shri. Sudhanshu Srivastava

For Appellant: None (Written submission)For Respondent: Shri Sanjeev Krishna Sharma and Shri Amit Kumar, D.Rs
Section 143(3)Section 244ASection 271(1)(c)Section 28Section 80PSection 80P(2)(a)

price to its member cane growers by mills. c. Marketing of the sugar cane, an agricultural produce, grown by the appellant's members. d. To provide seeds, fertilizers pesticides, agricultural equipments to members. e. To provide credits to the members. f. To arrange funds and finance for activities of the society. (Note: a copy of relevant part of the said