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13 results for “transfer pricing”

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Key Topics

Section 43B21 Addition to Income11 Section 143(3)9 Deduction7 Section 1156 Section 2636 Section 92C6 Disallowance5 Transfer Pricing4

SCORPIO IRON LTD,PANAJI vs. ITO, WARD - 1(4), PANAJI

In the result, both appeals of the assessee are allowed

ITA 388/PAN/2017[2013-14]Status: DisposedITAT Panaji07 Oct 2021AY 2013-14

For Appellant: Shri Shrinivas Nayak, CAFor Respondent: Shri Sourabh Nayak, Sr. DR

Section 143(3)Section 92ASection 92C

price has been determined has been provided. Thus, entire transfer pricing document was filed to justify arm's length price

SHREE AMBEY FORGING PRIVAT LIMITED,PANAJI vs. ITO, WARD - (4), PANAJI

In the result, both appeals of the assessee are allowed

ITA 389/PAN/2017[2013-14]Status: Disposed

Natural Justice3

Section 144C(5)2

ITAT Panaji

07 Oct 2021

AY 2013-14

For Appellant: Shri Shrinivas Nayak, CAFor Respondent: Shri Sourabh Nayak, Sr. DR

Section 143(3)Section 92ASection 92C

price has been determined has been provided. Thus, entire transfer pricing document was filed to justify arm's length price

GUALA CLOSURES (INDIA) PVT. LTD.,PANAJI vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, PANAJI., SELECT CITY

Appeal is dismissed in above terms

ITA 205/PAN/2019[2012-13]Status: DisposedITAT Panaji13 Oct 2023AY 2012-13

Bench: Shri Satbeer Singh Godara & Dr. Dipak Ripote

For Appellant: Shri Ketan VedFor Respondent: Shri P.S. Shivshankar, CIT-DR

Section 143(3)Section 144(3)Section 144CSection 253Section 263Section 4

Transfer Pricing Officer and a Draft Assessment Order u/s 144C of the Income Tax Act, 19G1 was passed on 23.02.2016 determining

GUALA CLOSURES (INDIA) PVT. LTD.,PANAJI vs. THE INCOME TAX OFFICER, WARD - 1(1), PANAJI

In the result, the appeal filed by the assessee is partly allowed for statistical purpose

ITA 344/PAN/2017[2013-14]Status: DisposedITAT Panaji02 Apr 2026AY 2013-14

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A.No.344/Pan/2017 (A.Y.2013-14 ) Guala Closures(India) Vs. I T O Ward1(1), Private Limited, Aaykar Bhavan, D-1, Sesa Ghor, Edc, Patto, 20,Edc Complex, Panjim-403001. Patto, Goa. Panaji-403001, Goa Pan/Gir No.:Aaacg4447J Appellant .. Respondent

For Appellant: Shri.Niraj Sheth. ARFor Respondent: Shri.Renga Ranjan.CIT DR

Section 115Section 143(3)Section 144C(5)Section 2(43)Section 4Section 90

Transfer Pricing Officer (TPO) for determination of Arm’s Length Price (ALP). The TPO on receipt of the directions of the A.O. has called

GUALA CLOSURES (INDIA) PVT. LTD.,PANAJI vs. THE INCOME TAX OFFICER, WARD-1(1), PANAJI., PANAJI

In the result, the appeal filed by the assessee is partly allowed for statistical purpose

ITA 62/PAN/2017[2012-13]Status: DisposedITAT Panaji29 Jul 2025AY 2012-13

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A.No.62/Pan/2017 (A.Y.2012-13 ) Guala Closures(India) Vs. I T O Ward1(1), Private Limited, Aaykar Bhavan, D-1, Seasa Ghor, Edc, Patto, 20,Edc Complex, Panjim-403001. Patto, Goa. Panaji-403001, Goa Pan/Gir No.:Aaacg4447J Appellant .. Respondent

For Appellant: Shri.Nirajsheth. ARFor Respondent: Shri.Satish M .CIT DR

Section 115Section 143(3)Section 144C(5)

Transfer Pricing Officer (TPO) for determination of Arm’s Length Price (ALP). The TPO on receipt of the directions of the A.O. has called

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, PANAJI vs. M/S SALITHO ORES PVT. LTD, PANAJI

In the result, appeal of the assessee is allowed

ITA 100/PAN/2018[2013-14]Status: DisposedITAT Panaji21 Sept 2023AY 2013-14

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury(Through Virtual Hearing) M/S. Salitho Ores Pvt. Ltd., Vs Acit, Circle-1, Salgaocar Bhavan, Altinho, Margao Panaji, Goa. Pan: Aabcs 8859 F Appellant Respondent

For Appellant: Shri P.J. Pardiwalla, CAFor Respondent: Shri Prabhakar Anand DJ, DR

transfers his goods to another trader at a price less than the market price, the taxing authority cannot take into

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, PANAJI vs. M/S SALITHO ORES PVT. LTD, PANAJI

In the result, appeal of the assessee is allowed

ITA 99/PAN/2018[2012-13]Status: DisposedITAT Panaji21 Sept 2023AY 2012-13

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury(Through Virtual Hearing) M/S. Salitho Ores Pvt. Ltd., Vs Acit, Circle-1, Salgaocar Bhavan, Altinho, Margao Panaji, Goa. Pan: Aabcs 8859 F Appellant Respondent

For Appellant: Shri P.J. Pardiwalla, CAFor Respondent: Shri Prabhakar Anand DJ, DR

transfers his goods to another trader at a price less than the market price, the taxing authority cannot take into

M/S SALITHO ORES PRIVATE LIMITED,PANAJI vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE - M1, MARGAO

In the result, appeal of the assessee is allowed

ITA 72/PAN/2018[2014-15]Status: DisposedITAT Panaji21 Sept 2023AY 2014-15

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury(Through Virtual Hearing) M/S. Salitho Ores Pvt. Ltd., Vs Acit, Circle-1, Salgaocar Bhavan, Altinho, Margao Panaji, Goa. Pan: Aabcs 8859 F Appellant Respondent

For Appellant: Shri P.J. Pardiwalla, CAFor Respondent: Shri Prabhakar Anand DJ, DR

transfers his goods to another trader at a price less than the market price, the taxing authority cannot take into

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1), PANAJI., PANAJI vs. M/S ANDREW TELECOMMUNICATION INDIA PVT. LTD., VERNA

In the result, the appeal filed by the Revenue is dismissed

ITA 188/PAN/2018[2011-12]Status: DisposedITAT Panaji17 Aug 2022AY 2011-12

Bench: Shri C.M. Garg & Shri Girish Agrawalassessment Year: 2011-12 Acit, Vs. M/S Andrew Telecommunications Circle-2(1), India Pvt. Ltd., Panaji, Plot No.N2, Andrew Phase Iv, Goa. Verna Industrial Estate, Verna, Goa. Pan: Aabca8820A (Appellant) (Respondent) Assessee By : Shri Ketan Ved, Ca Revenue By : Shri Ranjan Kumar, Cit, Dr Date Of Hearing : 15.06.2022 Date Of Pronouncement : 17.08.2022 Order Per C.M. Garg, Jm: This Appeal Has Been Filed By The Revenue Against The Order Of The Cit(A), Panaji—1, Dated 08.02.2018 For Assessment Year 2011-12. 2. The Grounds Of Appeal Taken By The Revenue Read As Under:- “1. Whether The Cit(A) Has Rightly Allowed The All Grounds Of Appeal Of The Assessee Without Appreciating The Fact Draft Assessment Order Is Relevant For Addition On Account Of Tp Adjustment. 2. Whether The Cit(A) Has Rightly Allowed The Grounds Of Appeal With Respect To Additions Made By The Ao Other Than Tp Adjustment, Without Going To Merit Of The Case. 3. For These & Other Grounds That May Be Adduced At The Time Of The Hearing The Order Of The Cit(A) May Be Set Aside & The Order Of The Assessing Order Restored.”

For Appellant: Shri Ketan Ved, CAFor Respondent: Shri Ranjan Kumar, CIT, DR

Section 143CSection 144C

Transfer Pricing Officer took charge of the Assessee's case and he passed an order without issuing any show cause

BEIERSDORF INDIA (P) LTD.,PANAJI vs. INCOME TAX OFFICER, WARD - 2(4),, PANAJI

In the result, appeal of assessee is partly allowed

ITA 337/PAN/2018[2014-15]Status: DisposedITAT Panaji17 Aug 2022AY 2014-15

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawal

For Appellant: Sh D.E. Robinson, AdvocateFor Respondent: Sh Ranjan Kumar, CIT-DR

Section 28Section 36Section 43Section 43(5)

transfer of such warehouse receipts, by the broker. The payouts being made by the clearing house on settlement dates. The difference between the selling price

SALGAOCAR MINING INDUSTRIES PRIVATE LIMITED.,PANAJI vs. THE JOINT COMMISSIONER OF INCOME TAX, MARGAO RANGE., MARGAO

In the result, the appeal filed by the Revenue in ITA

ITA 118/PAN/2016[2011-12]Status: DisposedITAT Panaji05 Oct 2023AY 2011-12

Bench: SHRI INTURI RAMA RAO (Accountant Member), SHRI PARTHA SARATHI CHAUDHURY (Judicial Member)

For Appellant: Shri Sukhsagar SyalFor Respondent: Shri Prabhakar Anand

Section 143(3)Section 14ASection 41(1)

price in instalment. In respect of these parties, the assessee paid service charges to the contractor out of which amount of the machineries was deducted and balance amount was shown as liability in the books of accounts which is adjusted at the time of the transfer

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, MARGAO., MARGAO vs. M/S SALGAONCAR MINING INDUSTRIES PVT. LTD., PANAJI

In the result, the appeal filed by the Revenue in ITA

ITA 135/PAN/2016[2011-12]Status: DisposedITAT Panaji05 Oct 2023AY 2011-12

Bench: SHRI INTURI RAMA RAO (Accountant Member), SHRI PARTHA SARATHI CHAUDHURY (Judicial Member)

For Appellant: Shri Sukhsagar SyalFor Respondent: Shri Prabhakar Anand

Section 143(3)Section 14ASection 41(1)

price in instalment. In respect of these parties, the assessee paid service charges to the contractor out of which amount of the machineries was deducted and balance amount was shown as liability in the books of accounts which is adjusted at the time of the transfer

VIJESH VITHAL TALAULICAR,PANAJI vs. ACIT, CIRCLE - 1(1), PANAJI

In the result, appeal of the assessee is allowed in terms of our aforesaid observations

ITA 230/PAN/2017[2010-11]Status: DisposedITAT Panaji31 Mar 2022AY 2010-11

Bench: Shri Ravish Sood & Shri Jamlappa D Battullआयकर अपील सं. / Ita No. 230/Pan/2017 "नधा"रण वष" / Assessment Year : 2010-11 Shri Vijesh Vithal Talaulicar Shri Ramnath Sadan, Dr. Dada Vaidya Road, Panaji, Goa Pan : Aaxpt9647D .......अपीलाथ" / Appellant बनाम / V/S. The Asst. Commissioner Of Income Tax, Circle-1(1), Panaji. ……""यथ" / Respondent

For Appellant: Shri D.E. Robinson, ARFor Respondent: Shri Sourabh Nayak, Sr. DR

Section 143(2)Section 143(3)

transfer the aforementioned 10,000 equity shares. It was further submitted by the assessee, that as per the terms of the aforesaid ‘agreement’ the rejection of dump lying outside the mining area would continue to belong to sellers alongwith all future rejection dump that would be generated. Backed by the aforesaid facts, it was claimed by the assessee that pursuant