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12 results for “transfer pricing”+ Section 22Aclear

Sorted by relevance

Delhi14Mumbai12Lucknow8Hyderabad4Telangana2Indore2Karnataka2Nagpur2Amritsar1SC1Bangalore1

Key Topics

Section 4014Section 143(3)8Disallowance8Section 14A7Deduction6Depreciation6Section 153C4Addition to Income4Double Taxation/DTAA3

MACQUIE HOLDINGS B.V. & CO. KG,MUMBAI vs. DCIT (IT) 3(2)(1), MUMBAI

In the result, appeal is partly allowed

ITA 2572/MUM/2017[2013-14]Status: DisposedITAT Mumbai12 Apr 2019AY 2013-14

Bench: Shri Saktijit Dey & Shri Manoj Kumar Aggarwal

For Appellant: Shri Milin ThakoreFor Respondent: Shri Manoj Kumar
Section 143(3)Section 144C(13)Section 144C(15)Section 144C(15)(b)

Transfer Pricing Officer. Therefore, the first condition of section 144C(15)(b) of the Act is not satisfied. Thus, it requires to be seen whether the assessee can fit into the definition of a foreign company as provide du/s 144C(15)(b)(ii) of the Act. As per the definition of foreign company under section

Section 682
Section 792
Capital Gains2

SHINHAN BANK,MUMBAI vs. DCIT (IT) 4(2)(1), MUMBAI

In the result, the cross-objection is dismissed

ITA 2227/MUM/2017[2013-14]Status: DisposedITAT Mumbai09 Nov 2022AY 2013-14
Section 143(3)

22A), a domestic company is defined as “an Indian company or any other company, which in respect of its income liable to tax in India makes prescribed arrangements for declaration and payment of dividends within India”, and Section 2(23A), a foreign company is defined as a company “which is not a domestic company” i.e. which has not made prescribed

SHINHAN BANK,MUMBAI vs. DCIT (IT) 4(2)(1), MUMBAI

In the result, the cross-objection is dismissed

ITA 2229/MUM/2017[2012-13]Status: DisposedITAT Mumbai09 Nov 2022AY 2012-13
Section 143(3)

22A), a domestic company is defined as “an Indian company or any other company, which in respect of its income liable to tax in India makes prescribed arrangements for declaration and payment of dividends within India”, and Section 2(23A), a foreign company is defined as a company “which is not a domestic company” i.e. which has not made prescribed

MUMBAI INTERNATIONAL AIRPORT P.LTD,MUMBAI vs. ADDL CIT RG 8(2), MUMBAI

In the result, assessee’s appeals are statistically allowed and revenue’s

ITA 4911/MUM/2013[2010-11]Status: DisposedITAT Mumbai13 Nov 2017AY 2010-11

Bench: Shri P K Bansal & Shri Pawan Singh

For Appellant: Shri Vijay MehtaFor Respondent: Shri Anand Mohan
Section 14ASection 40

price was transferred to a separate fund for building up adequate storage facilities under a statutory obligation, it was held to be diverted at source by overriding title could not form part of assessee’s income. 14.42. Ld. Counsel had also relied upon before us the judgment of Hon’ble Madras High Court in the case of CIT vs Salem

DCIT 8(2), MUMBAI vs. MUMBAI INTERNATIONAL AIRPORT P. LTD, MUMBAI

In the result, assessee’s appeals are statistically allowed and revenue’s

ITA 5655/MUM/2014[2011-12]Status: DisposedITAT Mumbai13 Nov 2017AY 2011-12

Bench: Shri P K Bansal & Shri Pawan Singh

For Appellant: Shri Vijay MehtaFor Respondent: Shri Anand Mohan
Section 14ASection 40

price was transferred to a separate fund for building up adequate storage facilities under a statutory obligation, it was held to be diverted at source by overriding title could not form part of assessee’s income. 14.42. Ld. Counsel had also relied upon before us the judgment of Hon’ble Madras High Court in the case of CIT vs Salem

MUMBAI INTERNATIONAL AIRPORT P. LTD,MUMBAI vs. ADDL CIT 8(2), MUMBAI

In the result, assessee’s appeals are statistically allowed and revenue’s

ITA 4784/MUM/2014[2011-12]Status: DisposedITAT Mumbai13 Nov 2017AY 2011-12

Bench: Shri P K Bansal & Shri Pawan Singh

For Appellant: Shri Vijay MehtaFor Respondent: Shri Anand Mohan
Section 14ASection 40

price was transferred to a separate fund for building up adequate storage facilities under a statutory obligation, it was held to be diverted at source by overriding title could not form part of assessee’s income. 14.42. Ld. Counsel had also relied upon before us the judgment of Hon’ble Madras High Court in the case of CIT vs Salem

DCIT 8(2), MUMBAI vs. MUMBAI INTERNATIONAL AIRPORT P.LTD, MUMBAI

In the result, assessee’s appeals are statistically allowed and revenue’s

ITA 5592/MUM/2013[2010-11]Status: DisposedITAT Mumbai13 Nov 2017AY 2010-11

Bench: Shri P K Bansal & Shri Pawan Singh

For Appellant: Shri Vijay MehtaFor Respondent: Shri Anand Mohan
Section 14ASection 40

price was transferred to a separate fund for building up adequate storage facilities under a statutory obligation, it was held to be diverted at source by overriding title could not form part of assessee’s income. 14.42. Ld. Counsel had also relied upon before us the judgment of Hon’ble Madras High Court in the case of CIT vs Salem

MUMBAI INTERNATIONAL AIRPORT P.LTD,MUMBAI vs. ADDL CIT RG 8(20, MUMBAI

In the result, assessee’s appeals are statistically allowed and revenue’s

ITA 1081/MUM/2013[2009-10]Status: DisposedITAT Mumbai13 Nov 2017AY 2009-10

Bench: Shri P K Bansal & Shri Pawan Singh

For Appellant: Shri Vijay MehtaFor Respondent: Shri Anand Mohan
Section 14ASection 40

price was transferred to a separate fund for building up adequate storage facilities under a statutory obligation, it was held to be diverted at source by overriding title could not form part of assessee’s income. 14.42. Ld. Counsel had also relied upon before us the judgment of Hon’ble Madras High Court in the case of CIT vs Salem

DCIT 8(2), MUMBAI vs. MUMBAI INTERNAIOTNAL AIRPORT P.LTD, MUMBAI

In the result, assessee’s appeals are statistically allowed and revenue’s

ITA 4675/MUM/2013[2009-10]Status: DisposedITAT Mumbai13 Nov 2017AY 2009-10

Bench: Shri P K Bansal & Shri Pawan Singh

For Appellant: Shri Vijay MehtaFor Respondent: Shri Anand Mohan
Section 14ASection 40

price was transferred to a separate fund for building up adequate storage facilities under a statutory obligation, it was held to be diverted at source by overriding title could not form part of assessee’s income. 14.42. Ld. Counsel had also relied upon before us the judgment of Hon’ble Madras High Court in the case of CIT vs Salem

M/S. SIMTOOLS PVT. LTD.,MUMBAI vs. DCIT , CENTRAL CIRCLE-7(3) ( EARSTWHILE DCIT- CENT. CIR-42), MUMBAI

In the result, this appeal by the assessee stands allowed as above

ITA 1574/MUM/2020[2011-12]Status: DisposedITAT Mumbai09 Feb 2022AY 2011-12

Bench: Shri Shamim Yahya & Shri Amarjit Singh

For Appellant: Shri Anuj KisnadwalaFor Respondent: Shri Vinay Sinha
Section 132(4)Section 153CSection 32(1)Section 79

price was brought down viz-a-viz market value. Even the flats which are sold almost in the same period had different rates as per agreement where there was no SCUD meeting the rates charged were higher viz-a-viz the rates fixed after SCUD meeting. Taking into consideration this factor, Mr. Abhinandan Lodha made a disclosure of Rs.51 Crore

JITENDRA SHARMA, ACIT, CIRCLE-19(1), MUMBAI, MUMBAI vs. KASHYAP MAHESH VORA, MUMBAI

In the result, the appeal of the revenue bearing ITA No

ITA 4322/MUM/2024[2012]Status: DisposedITAT Mumbai10 Jul 2025

Bench: BEFOR SHRI ANIKESH BANERJEE (Judicial Member), SMT. RENU JAUHRI (Accountant Member)

For Appellant: Shri K. Gopal a/w Shri AkhileshFor Respondent: Shri Hemanshu Joshi, SR DR
Section 143(3)Section 147Section 250Section 68Section 69C

22A, Walkeshwar Road, Mumbai- Chamber, Lalbaug, Mumbai- 400 006 400 012 PAN: ABXPV1914E APPELLANT RESPONDENT Assessee by : Shri K. Gopal a/w Shri Akhilesh Deshmukh Respondent by : Shri Hemanshu Joshi, SR DR Date of hearing : 03/07/2025 Date of pronouncement : 10/07/2025 O R D E R PER ANIKESH BANERJEE, J.M: The instant appeal of the revenue was filed against the order

MUMBAI INTERNATIONAL AIRPORT P.LTD,MUMBAI vs. DCIT 10(2)(2), MUMBAI

In the result, appeal filed by the revenue is dismissed

ITA 2018/MUM/2018[2013-14]Status: DisposedITAT Mumbai10 Jan 2020AY 2013-14

Bench: Shri G. Manjunatha & Shri Ravish Soodmumbai International Airport Vs. Dcit,Circle-10(2)(2) Private Limited Room No.209,Aaykar Bhawan Finance Department M.K.Road 1St Floor, Terminal 1B Mumbai-400 020 Chhatrapati Shivaji Internaitonal Airport Santacruz (E) Mumbai-400 099 Pan/Gir No.Aaecm6285C (Appellant) .. (Respondent) & Dcit-10(2)(2) Vs. Mumbai International Room No.216-A,Aaykar Bhawan Airport Private Limited M.K.Road Finance Department, 1St Floor, Terminal 1B Mumbai-400 020 Chhatrapati Shivaji Internaitonal Airport Santacruz (E) Mumbai-400 099

Section 143(3)Section 14ASection 40

section (1) of section 13 of the Airports Economic Regulatory Authority of India Act, 2008” 14.30. In pursuance to the aforesaid rule, an order dated 09th May, 2006 was issued by concerned official of MOCA which reads as under:- “ ORDER Subject: Collection of Passenger Service Fee (PSF) at. Greenfield / Private airports - regarding Consequent to allowing private companies, Joint Venture. Companies