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10 results for “transfer pricing”+ Set Off of Lossesclear

Sorted by relevance

Mumbai3,045Delhi2,921Bangalore1,258Chennai636Kolkata606Ahmedabad509Pune472Karnataka362Jaipur303Hyderabad287Chandigarh185Indore170Cochin150Rajkot90Visakhapatnam87Surat83SC50Calcutta47Lucknow45Nagpur42Raipur41Telangana40Cuttack36Guwahati29Jodhpur28Dehradun23Amritsar20Agra12Panaji10Varanasi10Ranchi8Jabalpur7Kerala4A.K. SIKRI ROHINTON FALI NARIMAN4Allahabad4Orissa4Rajasthan2T.S. THAKUR ROHINTON FALI NARIMAN1Punjab & Haryana1Andhra Pradesh1Patna1

Key Topics

Section 43B21Addition to Income8Section 143(3)7Section 2636Section 92C6Deduction5Disallowance5Transfer Pricing3Section 14A2

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. Now, coming to the issue of applicability of provision of section 14A, the assessee before the Assessing Officer has filed all the relevant details for investment made in mutual funds

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

In the result, both appeals of the assessee are allowed

Section 41(1)2
Section 43(5)2
Section 362
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 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. Now, coming to the issue of applicability of provision of section 14A, the assessee before the Assessing Officer has filed all the relevant details for investment made in mutual funds

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

setting aside the assessment order to the file of the Assessing Officer for making a fresh assessment on the issue of royalty expenditure of Rs.31,26,55,634. 5. The Hon'ble Pr. CIT erred in not appreciating that the expenditure incurred on royalty wasnot for acquiring or bringing into existence an asset which gives an advantage for the enduring

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

Loss account is not affected by this account ". The assessee did not file any evidence in support of its claim and it appears that the assessee has no substantive evidence to produce in support of the claim made in its reply. The assessee has thus failed to explain the claim of royalty debited to the P & L account amounting

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

Loss account is not affected by this account ". The assessee did not file any evidence in support of its claim and it appears that the assessee has no substantive evidence to produce in support of the claim made in its reply. The assessee has thus failed to explain the claim of royalty debited to the P & L account amounting

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

Loss account is not affected by this account ". The assessee did not file any evidence in support of its claim and it appears that the assessee has no substantive evidence to produce in support of the claim made in its reply. The assessee has thus failed to explain the claim of royalty debited to the P & L account amounting

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

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, MARGAO., MARGAO vs. M/S SALGAONCAR MINING INDUSTRIES PVT. LTD., PANAJI

In the result, the appeal filed by the Revenue in ITA

ITA 135/PAN/2016[2011-12]Status: DisposedITAT Panaji05 Oct 2023AY 2011-12

Bench: SHRI INTURI RAMA RAO (Accountant Member), SHRI PARTHA SARATHI CHAUDHURY (Judicial Member)

For Appellant: Shri Sukhsagar SyalFor Respondent: Shri Prabhakar Anand
Section 143(3)Section 14ASection 41(1)

Loss Account which remains unpaid as on 31.03.2011. The details of such provisions are set out by the Assessing Officer vide para 6 of the assessment order. The Assessing Officer inferred that since the expenses were not incurred till the date, the provisions for such expense cannot be allowed as deduction. Accordingly, disallowed the provisions of expenses of Rs.2

SALGAOCAR MINING INDUSTRIES PRIVATE LIMITED.,PANAJI vs. THE JOINT COMMISSIONER OF INCOME TAX, MARGAO RANGE., MARGAO

In the result, the appeal filed by the Revenue in ITA

ITA 118/PAN/2016[2011-12]Status: DisposedITAT Panaji05 Oct 2023AY 2011-12

Bench: SHRI INTURI RAMA RAO (Accountant Member), SHRI PARTHA SARATHI CHAUDHURY (Judicial Member)

For Appellant: Shri Sukhsagar SyalFor Respondent: Shri Prabhakar Anand
Section 143(3)Section 14ASection 41(1)

Loss Account which remains unpaid as on 31.03.2011. The details of such provisions are set out by the Assessing Officer vide para 6 of the assessment order. The Assessing Officer inferred that since the expenses were not incurred till the date, the provisions for such expense cannot be allowed as deduction. Accordingly, disallowed the provisions of expenses of Rs.2

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)

loss, total or partial of a capital asset would be a capital receipt." However , the said decision is not applicable to the facts of the case. The sale price received by the appellant is for sale of ore rejects dumped on the Dharnbandora plot, it does not pertain to sale of any part of or rights in the Dharnbandora plot