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7 results for “transfer pricing”+ Section 17(1)(iv)clear

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Key Topics

Section 43B21Addition to Income7Section 2636Disallowance5Section 143(3)4Section 144C3Deduction3Section 14A2Section 41(1)2

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 of the ownership. Based on this submission, the ld. CIT(A) concluded that there

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

Transfer Pricing2

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 of the ownership. Based on this submission, the ld. CIT(A) concluded that there

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

17 ITA.No.205/PAN./2019 (7) The Dispute Resolution Panel may, before issuing any directions referred to in sub-section (5),- (a) make such further enquiry, as it thinks fit; or (b) cause any further enquiry to be made by any income-tax authority and report the result of the same to it. (8) The Dispute Resolution Panel may confirm, reduce

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

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

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

17,297/- cannot be sustained and hence, is deleted. Ground No.2 is allowed.” 4. The Department in this ground substantially had contended that there has been a violation of Rule 46A(3) of the Income Tax Rules, 1962 by the ld. CIT(A) in admission of additional evidences produced by the assessee. That, on merits of the addition u/sec

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

17,297/- cannot be sustained and hence, is deleted. Ground No.2 is allowed.” 4. The Department in this ground substantially had contended that there has been a violation of Rule 46A(3) of the Income Tax Rules, 1962 by the ld. CIT(A) in admission of additional evidences produced by the assessee. That, on merits of the addition u/sec

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

17,297/- cannot be sustained and hence, is deleted. Ground No.2 is allowed.” 4. The Department in this ground substantially had contended that there has been a violation of Rule 46A(3) of the Income Tax Rules, 1962 by the ld. CIT(A) in admission of additional evidences produced by the assessee. That, on merits of the addition u/sec