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13 results for “transfer pricing”+ Section 142A(6)clear

Sorted by relevance

Chandigarh31Delhi22Agra17Mumbai13Chennai10Nagpur7Indore6Jaipur6Bangalore4Pune4Hyderabad3Kolkata3Ahmedabad2SC2Lucknow1Surat1Cochin1Cuttack1

Key Topics

Section 14816Section 69C10Section 143(3)9Section 1519Section 43C7Addition to Income7Section 1476Reassessment5Reopening of Assessment

MR. SATYA PRAKASH SINGH,MUMBAI vs. ITO, WARD-28(3)(1), VASHI

In the result, the ground so taken by the assessee so far as it relates to challenging the order of the AO as passed beyond the period of limitation is hereby allowed

ITA 3715/MUM/2023[2012-13]Status: DisposedITAT Mumbai08 Aug 2025AY 2012-13

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

For Appellant: Shri Rushabh MehtaFor Respondent: Shri Arun Kanti Datta, CIT-DR
Section 143(3)Section 153Section 69C

Transfer Pricing Officer is received by him. (6) Nothing contained in sub-sections (1) 16[, (1A)] and (2) shall apply to the following classes of assessments, reassessments and recomputation which may, subject to the provisions of sub-sections (3), (5) and (5A), be completed— where the assessment, reassessment or recomputation is made on the assessee (i) or any person

5
Section 56(2)(vii)4
Section 1533
Disallowance3

ITO-28(3)(1), MUMBAI, MUMBAI vs. SATYA PRAKASH SINGH, MUMBAI

In the result, the ground so taken by the assessee so far as it relates to challenging the order of the AO as passed beyond the period of limitation is hereby allowed

ITA 3844/MUM/2025[2012]Status: DisposedITAT Mumbai08 Aug 2025

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

For Appellant: Shri Rushabh MehtaFor Respondent: Shri Arun Kanti Datta, CIT-DR
Section 143(3)Section 153Section 69C

Transfer Pricing Officer is received by him. (6) Nothing contained in sub-sections (1) 16[, (1A)] and (2) shall apply to the following classes of assessments, reassessments and recomputation which may, subject to the provisions of sub-sections (3), (5) and (5A), be completed— where the assessment, reassessment or recomputation is made on the assessee (i) or any person

TESSITURA MONTI INDIA P.LTD,MUMBAI vs. ASST CIT (OSD) 8(3), MUMBAI

In the result, the appeal by the assessee is allowed for statistical purposes

ITA 799/MUM/2015[2010-11]Status: DisposedITAT Mumbai12 Dec 2022AY 2010-11

Bench: Shri M. Balaganesh & Shri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Samuel Pitta
Section 143(3)Section 144C(5)

6. The assessee filed detailed objections before the learned DRP against the adjustment proposed by the TPO/AO. During the proceedings before the learned DRP, the assessee filed the valuation report from the Chartered Engineer in Italy, wherein the purchase price of the plant and machinery was certified to be reasonable. The learned DRP rejected the valuation report submitted

ACC LTD.,MUMBAI vs. DCIT(LTU) - 1, MUMBAI

In the result, appeal filed by assessee is partly allowed

ITA 3135/MUM/2019[2009-10]Status: DisposedITAT Mumbai28 Feb 2023AY 2009-10

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

Section 143(3)Section 147Section 148Section 151Section 55A

price, made a reference to the DVO under Section 142A. The DVO estimated the market value of the property at an amount which was much higher than the amount shown in the document. The Assessing Officer added the difference between the two figures as undisclosed investment. It was in this background that this Court held that the report

DCIT(LTU) - 1, MUMBAI vs. ACC LTD., MUMBAI

In the result, appeal filed by assessee is partly allowed

ITA 3176/MUM/2019[2009-10]Status: DisposedITAT Mumbai28 Feb 2023AY 2009-10

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

Section 143(3)Section 147Section 148Section 151Section 55A

price, made a reference to the DVO under Section 142A. The DVO estimated the market value of the property at an amount which was much higher than the amount shown in the document. The Assessing Officer added the difference between the two figures as undisclosed investment. It was in this background that this Court held that the report

ACC LTD.,MUMBAI vs. DCIT(LTU) - 1, MUMBAI

In the result, appeal filed by assessee is partly allowed

ITA 3136/MUM/2019[2009-10]Status: DisposedITAT Mumbai28 Feb 2023AY 2009-10

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

Section 143(3)Section 147Section 148Section 151Section 55A

price, made a reference to the DVO under Section 142A. The DVO estimated the market value of the property at an amount which was much higher than the amount shown in the document. The Assessing Officer added the difference between the two figures as undisclosed investment. It was in this background that this Court held that the report

GOODWILL CONSTRUCTIONS,MUMBAI vs. DCIT, CIRCLE-1, , THANE

In the result, the appeal is allowed

ITA 3233/MUM/2022[2015-16]Status: DisposedITAT Mumbai11 Jun 2024AY 2015-16

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

For Appellant: Shri Subodh Ratnaparkhi, CAFor Respondent: Shri Mahesh Parwani, Sr. DR
Section 142A(1)Section 43C

transferred any land or building in the year under appeal, the provisions of section 43CA were not attracted and therefore the addition of Rs.24,47,250/- was required to be deleted. 2. The Hon. CIT (A) erred in confirming the addition of Rs. 24,47,250/- u/s 43CA of the I.T Act 1961, on account of difference between the actual

DCIT 2(3)(1), MUMBAI vs. HDFC BANK LIMITED, MUMBAI

Accordingly, (a) all the grounds raised by the Revenue are dismissed, (b) Cross Objection 1 (1

ITA 3372/MUM/2023[2015-16]Status: DisposedITAT Mumbai30 Sept 2024AY 2015-16

Bench: SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Yogesh Thar a/w ChaitanyaFor Respondent: Shri Biswanath Das
Section 143(3)Section 14ASection 153

Transfer Pricing Officer was directed not to pass final order. Thereafter, vide final order dated 20/12/2018 passed in the aforesaid writ petition [reported in (2019) 410 ITR 247], the Hon’ble Bombay High Court quashed the reference to the TPO. The Assessing Officer, thereafter, completed the assessment and passed Assessment Order on 15/02/2019. 4. The Assessee preferred appeal before

HARSHAD KUMAR AND BROS,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX 18 (1) , MUMBAI

In the result, the appeal of the Assessee is allowed in the aforesaid terms

ITA 408/MUM/2025[2013-2014]Status: DisposedITAT Mumbai30 Apr 2025AY 2013-2014

Bench: Shri Narender Kumar Choudhry & Shri Omkareshwar Chidaraassessment Year: 2013-14

For Appellant: Shri K. Gopal, Ld. A.R.a/wFor Respondent: Shri Hemanshu Joshi, Ld. D.R
Section 250Section 45Section 69B

price of the property for proposed addition u/s 69B of the Act. 5. Simultaneously the AO also referred the valuation of the property to DVO-I, Mumbai vide reference letter dated 25.02.2016. 6. The Assessee in the meantime in response to the show cause notice dated 07.03.2016, filed its reply substantiating the value of the property to the tune

ITO 2(3)(2), MUMBAI vs. SATURN ADVISORY SERVICES P.LTD, MUMBAI

The appeal of the Revenue is dismissed

ITA 802/MUM/2015[2006-07]Status: DisposedITAT Mumbai12 Sept 2017AY 2006-07

Bench: Shri Joginder Singh & Shri G. Manjunathaassessment Years: 2006-07 Income Tax Officer-2(3)(2), M/S Saturn Advisory Room No. 518A, Services Pvt. Ltd., बनाम/ Aayakar Bhavan, M.K. Road, 44, Strategic House, Vs. Mumbai-400020 Mint Road, Fort, Mumbai-400001 (राज"व /Revenue) ("नधा"रती/Assessee) Pan No.:-Aajcs2674N

Section 143(1)

section for determining the consideration actually received by the assessee would be applicable in all its rigour in such cases. This condition of 15% or more difference is merely intended to be a safeguard against the undue hardship which would be occasioned to the assessee if the inflexible rule of thumb enacted in sub-s. (2) were applied in marginal

ITO 7 (3)(4), MUMBAI vs. PUSHPAK HOMES PVT. LTD., MUMBAI

The appeal of the assessee is allowed and that of the Revenue is dismissed

ITA 1690/MUM/2019[2011-12]Status: DisposedITAT Mumbai23 Sept 2019AY 2011-12

Bench: Sri Mahavir Singh, Jm & Sri Rajesh Kumar, Am आयकर अपील सुं/ Ita No. 1449/Mum/2019 (यिर्ाारण बर्ा / Assessment Year 2011-12)

For Appellant: S/Shri Yogesh Thar
Section 143(3)Section 2(47)(ii)Section 50C

142A, 1st Floor, Aayakar Bhavan, / प्रत्यथााी M.K. Marg, Mumbai-400 020 अपीलाथाी की ओर े / Appellant by : S/Shri Yogesh Thar, Chaitnya D. Joshi, ARs ITA Nos. 1690 & 1449/Mum/2019 2 | P a g e प्रत्यथाी की ओर े / Respondent by : Ms Kusum Bansal, Departmental Representative ुिवाई की तारीख / Date of hearing: 26.06.2019 घोर्णा की तारीख / Date of pronouncement

PUSHPAK HOMES PVT. LTD.,MUMBAI vs. ITO 7 (1)(4), MUMBAI

The appeal of the assessee is allowed and that of the Revenue is dismissed

ITA 1449/MUM/2019[2011-12]Status: DisposedITAT Mumbai23 Sept 2019AY 2011-12

Bench: Sri Mahavir Singh, Jm & Sri Rajesh Kumar, Am आयकर अपील सुं/ Ita No. 1449/Mum/2019 (यिर्ाारण बर्ा / Assessment Year 2011-12)

For Appellant: S/Shri Yogesh Thar
Section 143(3)Section 2(47)(ii)Section 50C

142A, 1st Floor, Aayakar Bhavan, / प्रत्यथााी M.K. Marg, Mumbai-400 020 अपीलाथाी की ओर े / Appellant by : S/Shri Yogesh Thar, Chaitnya D. Joshi, ARs ITA Nos. 1690 & 1449/Mum/2019 2 | P a g e प्रत्यथाी की ओर े / Respondent by : Ms Kusum Bansal, Departmental Representative ुिवाई की तारीख / Date of hearing: 26.06.2019 घोर्णा की तारीख / Date of pronouncement

MRS. RUCHITA JINDAL,MUMBAI vs. DY COMM OF INCOME TAX, CENTRAL CIRCLE-3(3), MUMBAI

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

ITA 203/MUM/2023[2015-16]Status: DisposedITAT Mumbai17 May 2023AY 2015-16
For Appellant: Bhupendra ShahFor Respondent: C.T. Mathews
Section 142ASection 143(2)Section 148Section 234ASection 56(2)(vii)

section 56(2)(vii)(b). 4. In the facts and circumstances of the case and in law, the learned AO erred in making addition in AY 2015-16 instead of AY 2014-15. P a g e | 2 Mrs.Ruchita Jindal Vs. DCIT, CC 3(3) 5. In the facts and circumstances of the case and in law, the learned