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6 results for “transfer pricing”+ Section 10(15)clear

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Key Topics

Section 43B21Section 2636Addition to Income6Disallowance5Section 143(3)4Deduction3Section 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 adjustment were made by the TPO. These have been detailed in the assessment order para '7' of the assessment order referred above. The TP adjustment made by TPO were in total Rs. 10 ITA.No.205/PAN./2019 83,045,395/-. Assessee had made objection before the DRP and pursuant to DRP direction, the assessment was framed as per section

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

section itself becomes redundant and infructuous. Ld.DR also could not refute the said proposition of law as laid down by the Hon'ble Supreme Court (supra) by citing any decision favouring the Revenue. Accordingly, there is no infirmity in the order of the ld. CIT(A) on this issue and it is upheld. Hence, ground No.1 of the Revenue

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

section itself becomes redundant and infructuous. Ld.DR also could not refute the said proposition of law as laid down by the Hon'ble Supreme Court (supra) by citing any decision favouring the Revenue. Accordingly, there is no infirmity in the order of the ld. CIT(A) on this issue and it is upheld. Hence, ground No.1 of the Revenue

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

section itself becomes redundant and infructuous. Ld.DR also could not refute the said proposition of law as laid down by the Hon'ble Supreme Court (supra) by citing any decision favouring the Revenue. Accordingly, there is no infirmity in the order of the ld. CIT(A) on this issue and it is upheld. Hence, ground No.1 of the Revenue

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)

10 and Sl. No.22 found that the assessee had entered into a service cum purchase contract whereby the contractors were entitled to operate as well as a right to own the contract mining related machineries upon payments of contracted price in instalment. In respect of these parties, the assessee paid service charges to the contractor out of which amount

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)

10 and Sl. No.22 found that the assessee had entered into a service cum purchase contract whereby the contractors were entitled to operate as well as a right to own the contract mining related machineries upon payments of contracted price in instalment. In respect of these parties, the assessee paid service charges to the contractor out of which amount