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5 results for “transfer pricing”+ Section 271(1)(C)clear

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Key Topics

Section 43B21Section 92C6Addition to Income5Disallowance3Section 143(3)2Section 92A2Transfer Pricing2Exemption2Deduction2

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

C) of the Income Tax Act'1961 is without jurisdiction, misconceived and without following the principles of natural justice. 3) The Id. AO has erred in making adjustment / addition of Rs.9,73,68,545/- based on the order of the AO-TP u/s 92CA of the Income Tax Act'1961, in spite of the fact that the assesse or their

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

In the result, both appeals of the assessee are allowed

Natural Justice2
Comparables/TP2
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

C) of the Income Tax Act'1961 is without jurisdiction, misconceived and without following the principles of natural justice. 3) The Id. AO has erred in making adjustment / addition of Rs.9,73,68,545/- based on the order of the AO-TP u/s 92CA of the Income Tax Act'1961, in spite of the fact that the assesse or their

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