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7 results for “transfer pricing”+ Deductionclear

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Key Topics

Section 43B21Addition to Income7Section 2636Section 143(3)5Disallowance5Section 1154Deduction4Section 14A2Section 41(1)2

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 the total income of Rs.99,48,28,460/- including adjustment u/s 4 ITA.No.205/PAN./2019 92C on account of Payment of Management Fees of Rs.3,04,33,012/-. The assessee company filed objections before the Dispute Resolution Panel

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)

deduction of education cess on income tax and secondary and higher education cess payable for the year under consideration while computing the total income. (ii) To restrict the Dividend Distribution Tax (DDT) prescribed under the India-Netherlands tax treaty read with protocol to tax treaty and the excess DDT paid should be refunded along with the interest

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
Section 43B

transferred but the actual price that was received or fetched. Income which actually accrues is taxable. But income which the assessee could have but has not in fact earned cannot be taxed. We do not find any infirmity with the findings of the ld. CIT(A) which is upheld. Ground Nos. 2 & 3 of the Revenue’s appeals are dismissed

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
Section 43B

transferred but the actual price that was received or fetched. Income which actually accrues is taxable. But income which the assessee could have but has not in fact earned cannot be taxed. We do not find any infirmity with the findings of the ld. CIT(A) which is upheld. Ground Nos. 2 & 3 of the Revenue’s appeals are dismissed

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
Section 43B

transferred but the actual price that was received or fetched. Income which actually accrues is taxable. But income which the assessee could have but has not in fact earned cannot be taxed. We do not find any infirmity with the findings of the ld. CIT(A) which is upheld. Ground Nos. 2 & 3 of the Revenue’s appeals are dismissed

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

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