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2 results for “transfer pricing”+ Section 100clear

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BARUNEI ROLLER FLOUR MILL (P) LTD. vs. COMMISSIONER OF INCOME TAX (APPEALS) 1

In the result, the award of the maximum uniform rate for the

ITA/1/2022HC Orissa03 Nov 2023

Bench: DR. JUSTICE B.R.SARANGI (ACJ),MR. JUSTICE MURAHARI SRI RAMAN

100/- per sq.mtrs. for 1030 sq.mtrs. Page 41 of 99 The learned counsel submits that such a finding cannot be sustained in law and the learned Reference Court was in gross error, in inferring the existence of a fact on the ground that there was no rebuttal thereof. When the claimant failed to prove its case as regards severance

M/S.SHEETAL REAL vs. INCOME TAX OFFICER

In the result, the appeal fails and the substantial questions of law

ITA/83/2010HC Orissa08 Feb 2022

Bench: DR. JUSTICE S. MURALIDHAR (CJ),MR. JUSTICE R.K.PATTANAIK

Section 142(1)Section 143(1)
Section 143(2)
Section 143(3)
Section 260A
Section 372A

transfer thereof is short-term capital gains. Hence any period of less than 12 months, be it a few days or few months is of holding the shares does not make any difference, in any case, the transaction would result in short-term capital gains. Further the ITA/83/2010 REPORTABLE Page 39 of 60 assessee contended that short-term capital gains