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7 results for “transfer pricing”+ Section 9(1)(v)clear

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Delhi3,880Mumbai3,514Bangalore1,625Chennai886Kolkata675Ahmedabad643Hyderabad507Karnataka448Jaipur393Pune359Chandigarh252Indore227Cochin198Surat143Visakhapatnam115Rajkot108SC99Nagpur73Telangana73Cuttack65Calcutta65Lucknow63Raipur47Amritsar34Guwahati31Jodhpur29Agra29Dehradun28A.K. SIKRI ROHINTON FALI NARIMAN15Ranchi13Varanasi12Allahabad11Rajasthan10Kerala9Panaji7Patna6Jabalpur6Orissa6Punjab & Haryana3DIPAK MISRA V. GOPALA GOWDA1MADAN B. LOKUR S.A. BOBDE1S.B. SINHA MARKANDEY KATJU1A.K. SIKRI N.V. RAMANA1D.K. JAIN JAGDISH SINGH KHEHAR1T.S. THAKUR ROHINTON FALI NARIMAN1Andhra Pradesh1

Key Topics

Section 43B21Section 2636Section 92C6Addition to Income6Section 143(3)5Transfer Pricing3Deduction3Disallowance3Section 92A2

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

9) of section 10B. In the matter of General Finance Co. v. ACIT, which judgment has also been taken note of by the tribunal while repelling the contention raised by revenue with regard to retrospectivity of section 92BA(i) of the Act. Thus, when clause (i) of Section 92BA having been omitted by the Finance Act, 2017, with effect from

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

In the result, both appeals of the assessee are allowed

Exemption2
Natural Justice2
Comparables/TP2
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

9) of section 10B. In the matter of General Finance Co. v. ACIT, which judgment has also been taken note of by the tribunal while repelling the contention raised by revenue with regard to retrospectivity of section 92BA(i) of the Act. Thus, when clause (i) of Section 92BA having been omitted by the Finance Act, 2017, with effect from

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

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)

section 2(14) of the Income Tax Act; 1961, capital asset does not include any stock in trade. This; would cover the dead or non- moving stock in trade including scrap. Thus what is sold by appellant is non-moving stock or scrap of erstwhile business and the transactions are business transactions or adventure in the nature of trade