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6 results for “transfer pricing”+ Section 9(1)(v)clear

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Key Topics

Section 1662

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 and building, standing crops, trees, cultivation etc., whereafter, the Collector vide letter dated 31.10.2003, had sent the application to the Special Judicial Officer for disposal. The Collector he submitted, has stated in the Reference that the amount of compensation was determined Page 43 of 99 on the basis of fair market value, but however

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

9. … We fail to understand how a valid grievance can be made in respect of such deduction when the very extension of the benefit of set-off is itself a boon or a concession. It was open to the rule-making authority to provide for a small abridgement or curtailment while extending a concession. Viewed from this angle, the argument

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

9 (SC) ITA/83/2010 REPORTABLE Page 31 of 60 transaction was an adventure in the nature of trade or not and the answer to the question would depend in each case on the relevant factors and circumstances proved therein which will determine the character of the transactions. In support of such contention, reliance was placed on the decision of this Court

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

9,72,000/- (v) Loss of love and affection = Rs.25,000/- (vi) Funeral and transportation expenses = Rs.25,000/- Total Compensation Awarded = (iv+v+vi) Rs.10,22,000/- Accordingly, this issue is decided in favour of petitioners and against the respondents. VIRENDRA SINGH ADHIKARI 2026.02.09 18:06 I attest to the accuracy and integrity of this document

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 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

1) Whether, on the facts and in the circumstances of the case and in law, the Tribunal was justified in seeking exact comparability, which searching for comparable companies of the assessee under TNMM whereas the requirement of law and international jurisprudence require seeking similar comparable companies? 2) Whether, on the facts and in the circumstances of the case