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9 results for “transfer pricing”+ Section 3clear

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Key Topics

Section 2603Comparables/TP3Section 260A2Section 1662Transfer Pricing2

PRINCIPAL COMMISSIONER OF INCOME TAX 1 vs. INDUSTRIAL PROMOTION AND INVESTMENT CORPORATION OF ORISSA LTD.

Accordingly, the learned appellate authority has rightly dismissed the

ITA/15/2021HC Orissa31 Jan 2023

Bench: DR. JUSTICE S. MURALIDHAR (CJ),MR. JUSTICE MURAHARI SRI RAMAN

Section 107

price. 27. In that view of the matter, as it is admitted case of the petitioner that the electricity generated in 540 MW Power Plant is used in the course of or furtherance of his business, which is evident from Form G provided by the taxpayer i.e. the petitioner herein, the petitioner would not be entitled for ITC to electrical

ACIT, CIRCLE 1(2) vs. M/S. SERAJUDDIN AND CO.

The appeal is disposed of with liberty as prayed for by the learned counsel for

ITA/43/2022HC Orissa15 Mar 2023

Bench: DR. JUSTICE S. MURALIDHAR (CJ),MR. JUSTICE MURAHARI SRI RAMAN

Section 260

Section 260-A of the Income Tax Act, 1961 (for short, ‘the Act’) questioning the correctness and legality of order dated 12.10.2020 passed by the Income Tax Appellate Tribunal, ‘A’ Bench, Bengaluru (for short, ‘Appellate Authority’) in IT(TP)A.Nos.160 and 211/Bang/2016 for the assessment year 2011-12, raising the following substantial questions of law: “1. Whether

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

price of the land concerned.” 37. Having noticed the scope of Section 51-A of the LA Act as understood by this Court in V. Narasaiah case to be the correct interpretation, we will now consider whether such evidence is mandatory binding on the authority or the court concerned or it is only an enabling provision. 38. In relation

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 260ASection 372A

3,41,56,466/- for the assessment year 2005- 2006. The return was processed under section 143 (1) on 13 July 2006. The case was selected for scrutiny and notice under section 143 (2) was issued on 20 October 2006. Thereafter notices under section 142 (1) was issued on several dates and the case was discussed with the authorised representative

PRINCIPAL COMMISSIONER OF INCOME TAX-1 vs. INDIAN METALS AND FERRO ALLOYS LTD.

In the result, the substantial questions of law (i)

ITA/10/2021HC Orissa30 Jan 2023

Bench: : The Hon’Ble Acting Chief Justice T.S. Sivagnanam & The Hon’Ble Justice Hiranmay Bhattacharyya Date : 3Rd April, 2023 Appearance : Mr. Soumen Bhattacharjee, Adv. ...For The Appellant Mr. Asim Choudhury, Adv. Mr. Soham Sen, Adv. ...For The Respondent. The Court : This Appeal Filed By The Revenue Under Section 260A Of The Income Tax Act, 1961 (The ‘Act’ For Brevity) Is Directed Against The Order Dated October 17, 2018 Passed By The Income Tax Appellate Tribunal, “C” Bench, Kolkata (The Tribunal) In Ita No.524/Kol/2017 For The Assessment Year 2012-13. The Revenue Has Raised The Following Substantial Questions Of Law For Consideration:

Section 260ASection 32Section 92C

Transfer Pricing in respect of International Transactions” by TPO relied upon the decision in assessee’s own case for Assessment Year 2007-08 and 2008-09? 3 (v) Whether on the facts and circumstances of the case and on law Learned Income Tax Appellate Tribunal was justified in granting relief to the assessee on addition

PRINCIPAL COMMISSIONER OF INCOME TAX vs. M/S.AHINSA VINIMAY PVT.LTD.

ITA/132/2018HC Orissa05 Apr 2022

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

Section 260

3. The learned Tribunal, after discussing the rival contentions of both the Appellants-Revenue and Respondent-Assessee, has returned the findings as under: Date of Judgment 30-08-2018, ITA No.132/2018 Pr. Commissioner of Income Tax-5 & Another Vs. M/s Novo Nordisk India Pvt. Ltd., 5/11 Regarding Substantial Question of Law Nos.1 to 5: “7. Accentia Technologies Ltd., (‘Accentia

MAHESWAR PANDA vs. I.T.O., WARD-2(1)

ITA/48/2023HC Orissa15 Apr 2024

Bench: DR. JUSTICE B.R.SARANGI,MR. JUSTICE GOURISHANKAR SATAPATHY

Section 166

transferring the burden of paying the amount of compensation from respondent no.1-Insurance Company to the appellants herein.” 27. In the present matter, it is not the case that the victim himself was sitting on the mudguard of the tractor, rather he was sitting in the trolley which was used for the agricultural purpose as they were carrying the rice straw

PRINCIPAL COMMISSIONER OF INCOME TAX-1,BHUBANESWAR vs. SEKHAR KUMAR MOHAPATRA

ITA/9/2024HC Orissa15 Apr 2024

Bench: DR. JUSTICE B.R.SARANGI,MR. JUSTICE GOURISHANKAR SATAPATHY

For Appellant: Mr. Ajit Kumar, Sr. AdvocateFor Respondent: Mr. Prashant Vidyarthy, Sr. Panel Counsel
Section 164Section 42

3 total value including stamp duty and registration Rs. 70,575/- were purchased by Dr. Pradeep Kumar in his own name and in the name of Nand Lal HUF (Karta Rajendra Kumar), in the name of his brother Rajendra Kumar and Shyamal Chakraborty (present appellant) from the proceeds of crime which source of acquisition is not substantiated by them

PR.COMMISSIONER OF INCOME TAX,BHUBANESWAR vs. M/S.UTKAL ALUMINA INTERNATIONAL LTD.

ITA/10/2017HC Orissa04 Dec 2019

Bench: MR. JUSTICE K. S. JHAVERI (CJ),MR. JUSTICE K.R.MOHAPATRA

transfer by way of mortgage the urban land bearing No. A-I, Radhey Puri, Delhi-51. DW-2 22. Copy of Grant of mortgage permission in respect of plot no.8, Sector B &C for which loan has been sanctioned for construction of building thereon. DW-2 23. Copy of No objection certificate to mortgage the plot no.8, Sector