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7 results for “transfer pricing”+ Section 10(29)clear

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Key Topics

Section 143(3)8Deduction7Addition to Income7Section 1156Section 2636Section 92C6Transfer Pricing3Section 144C(5)2Section 42

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: DisposedITAT Panaji07 Oct 2021AY 2013-14
For Appellant: Shri Shrinivas Nayak, CAFor Respondent: Shri Sourabh Nayak, Sr. DR
Section 143(3)Section 92ASection 92C

10 Crore or more in an earlier assessment year and such adjustment has been upheld by the judicial authorities or is pending in appeal; and (c) where search and seizure or survey operations have been carried out under the provisions of the Income-tax Act and findings regarding transfer pricing issues in respect of international transactions or specified domestic transactions

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

In the result, both appeals of the assessee are allowed

Section 14A2
Section 41(1)2
Double Taxation/DTAA2
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

10 Crore or more in an earlier assessment year and such adjustment has been upheld by the judicial authorities or is pending in appeal; and (c) where search and seizure or survey operations have been carried out under the provisions of the Income-tax Act and findings regarding transfer pricing issues in respect of international transactions or specified domestic transactions

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 passed under sub-section (3) of section 92CA; and (ii) any non-resident not being a company, or any foreign company.] 18. A reading of the said section brings to the fore following:- The assessee has option to go to the DRP by filing objection before it. As per the provisions of section 144C

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

10% under Article 11 of the India -UK Tax Treaty. Upon the said question being answered the Department is at liberty to gross up the tax rate in an appropriate manner.” (Emphasis suppled) . Thus, 5. We considering the facts, submissions and ratio of the judicial decision restore this disputed issue for limited purpose to the file of the Assessing officer

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)

10% under the India-Netherlands tax treaty read with protocol treaty and the excess DDT paid should be refunded along with the interest. We find this disputed issue was decided by the Special Bench (Mumbai) in ITA. No 6997/Mum/2019 in the revenue appeal of DCIT Vs Total oil India Pvt Ltd & others vide order dated 20-4-2023.We considered it appropriate

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)

29,620/-. Against the said return of income, the assessment was completed by the Joint Commissioner of Income Tax, Margao Range, Margao (‘the Assessing Officer’) vide order dated 24.03.2014 passed u/s 143(3) of the Income Tax Act, 1961 (‘the Act’) at a total income of Rs.201,87,55,957/-. While doing so, the Assessing Officer made addition of Rs.24

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)

29,620/-. Against the said return of income, the assessment was completed by the Joint Commissioner of Income Tax, Margao Range, Margao (‘the Assessing Officer’) vide order dated 24.03.2014 passed u/s 143(3) of the Income Tax Act, 1961 (‘the Act’) at a total income of Rs.201,87,55,957/-. While doing so, the Assessing Officer made addition of Rs.24