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9 results for “transfer pricing”+ Section 4clear

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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

4) of the CGST Act. It is not the substantive right of the dealer to claim ITC, it is a kind of concession provided by the legislature on fulfillment of certain conditions mentioned in the provision. 24. The petitioner in Form G submitted Electricity Duty under the Electricity Duty Rules mentioning therein that 1388641 KWH Page

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

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

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

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-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

transferred amount to the firms owned by Sitaram Pathak and Inderlal Kejriwal, the money was credited to the account of Nand Lal HUF from M/s Rhea Enterprises which is controlled by Shyamal Chakravarty. As per statements of Rajesh Kumar Fogla under Section 164 Cr. P.C. and Vikas Khetan also, it transpires that the present appellant used to receive the bribe

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

transfer of shares of companies which were thinly traded and were highly illiquid and they are called as penny stocks. The period of holding of the shares is just above 12 months and the appreciation in price during this period was phenomenal. On an average transaction in the shares are shown to have been yielded 1129% returns during the period

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 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

4. Similarly, the learned Tribunal has considered other comparables and excluded the same. Regarding Substantial Question of Law No.6: “22.2.2. It is accepted principle that risk adjustment may be granted, as per law, if the assessee submits the computation thereof and substantiates the same. It is also an accepted principle, upheld in several decisions, that the adjustment