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5 results for “transfer pricing”+ Section 34clear

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Key Topics

Section 260A2

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

Transfer of Property Act, to advance the argument that the price component in a sale is an intrinsic and integral part of the transaction and a sale cannot exist without the price component and the price component in a sale transaction cannot be independent, whereas for a ‘collateral purpose’ it should be something i.e. independent and divisible from the main

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 of ₹34

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

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

34 of 60 senior standing counsel prayed for allowing the appeal and answering the substantial questions of law in favour of the revenue. 16. The assessee company filed their return of income on 31 October 2005 declaring a total income of Rs 3,41,56,466/- for the assessment year 2005- 2006. The return was processed under section

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