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7 results for “transfer pricing”+ Section 34clear

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Key Topics

Section 143(3)6Section 2636Section 92C6Addition to Income5Deduction4Transfer Pricing4Section 144C3Natural Justice3Section 1152

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

transfer price is consonance with the fair market price then conditions of this section gets satisfied. Hence applicability of section 80IA (8) has been examined by the Assessing Officer 34

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

In the result, both appeals of the assessee are allowed

Section 42
Section 43(5)2
Section 362
ITA 389/PAN/2017[2013-14]Status: Disposed
ITAT Panaji
07 Oct 2021
AY 2013-14
For Appellant: Shri Shrinivas Nayak, CAFor Respondent: Shri Sourabh Nayak, Sr. DR
Section 143(3)Section 92ASection 92C

transfer price is consonance with the fair market price then conditions of this section gets satisfied. Hence applicability of section 80IA (8) has been examined by the Assessing Officer 34

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

34) of the Act, since the burden of taxation has been shifted to the company distributing the dividend, from the shareholder. While the DDT is a tax payable by the company, and not the shareholders, in pith and substance, it is a tax on dividends that is income of the shareholders. 59. We must also note that BFAR has grossly

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

Transfer Pricing Officer took charge by observing thus :- “11. In view of the aforesaid decision of the Hon'ble Supreme Court and the other case laws, we are of the view that the new TPO should have given a show cause 3 notice and also the copy of the material gathered by him which he wanted to use against

BEIERSDORF INDIA (P) LTD.,PANAJI vs. INCOME TAX OFFICER, WARD - 2(4),, PANAJI

In the result, appeal of assessee is partly allowed

ITA 337/PAN/2018[2014-15]Status: DisposedITAT Panaji17 Aug 2022AY 2014-15

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawal

For Appellant: Sh D.E. Robinson, AdvocateFor Respondent: Sh Ranjan Kumar, CIT-DR
Section 28Section 36Section 43Section 43(5)

transfer of such warehouse receipts, by the broker. The payouts being made by the clearing house on settlement dates. The difference between the selling price and cost price of the commodities after deduction of brokerage was the income arising from this activity. It is not disputed by the AO that such income has been returned as business income

VIJESH VITHAL TALAULICAR,PANAJI vs. ACIT, CIRCLE - 1(1), PANAJI

In the result, appeal of the assessee is allowed in terms of our aforesaid observations

ITA 230/PAN/2017[2010-11]Status: DisposedITAT Panaji31 Mar 2022AY 2010-11

Bench: Shri Ravish Sood & Shri Jamlappa D Battullआयकर अपील सं. / Ita No. 230/Pan/2017 "नधा"रण वष" / Assessment Year : 2010-11 Shri Vijesh Vithal Talaulicar Shri Ramnath Sadan, Dr. Dada Vaidya Road, Panaji, Goa Pan : Aaxpt9647D .......अपीलाथ" / Appellant बनाम / V/S. The Asst. Commissioner Of Income Tax, Circle-1(1), Panaji. ……""यथ" / Respondent

For Appellant: Shri D.E. Robinson, ARFor Respondent: Shri Sourabh Nayak, Sr. DR
Section 143(2)Section 143(3)

transfer the aforementioned 10,000 equity shares. It was further submitted by the assessee, that as per the terms of the aforesaid ‘agreement’ the rejection of dump lying outside the mining area would continue to belong to sellers alongwith all future rejection dump that would be generated. Backed by the aforesaid facts, it was claimed by the assessee that pursuant