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7 results for “transfer pricing”+ Section 37clear

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Key Topics

Section 43B21Section 2636Section 92C6Addition to Income6Section 143(3)4Transfer Pricing3Deduction3Disallowance3Section 43(5)2

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

Transfer Pricing Officer-TPO under section 92CA could be invalid and bad in law. 7. It is for this precise reason, tribunal has rightly held that order passed by the TPO and DRP is unsustainable in the eyes of law. The said finding is based on the authoritative principles enunciated by the Hon'ble Supreme Court in Kolhapur Canesugar Works

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

In the result, both appeals of the assessee are allowed

Section 362
Section 432
Section 92A2
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 Pricing Officer-TPO under section 92CA could be invalid and bad in law. 7. It is for this precise reason, tribunal has rightly held that order passed by the TPO and DRP is unsustainable in the eyes of law. The said finding is based on the authoritative principles enunciated by the Hon'ble Supreme Court in Kolhapur Canesugar Works

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

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

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

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