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3 results for “transfer pricing”+ Section 32(1)(ii)clear

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Key Topics

Section 92C6Section 2636Section 143(3)4Transfer Pricing3Deduction3Addition to Income3Section 92A2Exemption2Natural Justice2

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

pricing adjustment made in the earlier assessment years have been set aside by the courts. Thus, when such conditions were not applicable and the Ld. CIT has also not specified as to which of the conditions laid down in the CBDT instructions have been violated or Assessing Officer has not followed the same, then no fault can be found

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

In the result, both appeals of the assessee are allowed

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

pricing adjustment made in the earlier assessment years have been set aside by the courts. Thus, when such conditions were not applicable and the Ld. CIT has also not specified as to which of the conditions laid down in the CBDT instructions have been violated or Assessing Officer has not followed the same, then no fault can be found

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