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21 results for “transfer pricing”+ Section 145clear

Sorted by relevance

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Key Topics

Section 12A44Section 1126Section 10(20)24Section 143(3)19Addition to Income14Section 143(2)9Exemption8Section 143(1)7Section 270A7

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(1),, PUNE vs. M/S. IAC INTERNATIONAL AUTOMOTIVE INDIA PVT.LTD,, PUNE

In the result, the appeal of the Revenue is dismissed

ITA 749/PUN/2022[2013-14]Status: DisposedITAT Pune08 Jul 2025AY 2013-14

Bench: Ms. Astha Chandra & Shree Dr. Dipak P. Ripote

For Appellant: Shri Darpan KirpalaniFor Respondent: Shri Madhukar Anand
Section 143(2)Section 92Section 92C

section 92CA(1) of the Act in order to determine the Arm‟s Length Price (“ALP”) in respect of such international transactions. 2.2 The assessee undertook the following international transactions with its AEs during AY 2013-14 and benchmarked each transaction by selecting the Most Appropriate Method (“MAM”) mentioned in the table below: Sr. Nature of International Amount

PRODAIR AIR PRODUCTS INDIA PRIVATE LIMITED, PUNE,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4, PUNE, PUNE

Showing 1–20 of 21 · Page 1 of 2

Section 2636
TDS6
Capital Gains4

In the result, the appeal of the Assessee is Dismissed

ITA 495/PUN/2022[2018-19]Status: DisposedITAT Pune14 Dec 2023AY 2018-19

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.495/Pun/2022 िनधा"रण वष" / Assessment Year : 2018-19 Prodair Air Products India The Assistant Private Limited, V Commissioner Of 602 Pentagon 5, Magarpatta S Income Tax, Circle-4, City, Hadapsar, Pune – 411013. Pune. Pan: Aafcp0045E Appellant/ Assessee Respondent /Revenue Assessee By Shri Chandni Shah & Ridhi Maru – Ar Revenue By Shri Subhakant Sahu – Irs, Dr Date Of Hearing 21/09/2023 Date Of Pronouncement 14/12/2023

Section 143(3)Section 144BSection 144CSection 274Section 92C

145/-. Since there Prodair Air Products India Pvt. Ltd., [A] was International transactions with the Associated Enterprise (AE) the case was referred to Transfer Pricing Officer (TPO) who passed an order under section92CA(3) on 24/07/2021 proposing an adjustment of Rs.3,41,50,685/- to the International transaction of Payment of Interest to AE on the Loan taken from

SPECTRAFORCE TECHNOLOGIES (INDIA) PRIVATE LIMITED,PUNE vs. ACIT, CIRCLE 5, PUNE, PUNE

In the result, appeal of the assessee is partly allowed for statistical purposes as per terms indicated hereinabove

ITA 2853/PUN/2024[AY 2021-22]Status: DisposedITAT Pune18 Jul 2025

Bench: Dr.Manish Borad & Ms. Astha Chandra

For Appellant: Shri S. Raghunathan and Shri Abhiroop Bhargav KFor Respondent: Shri Prakash L. Pathade
Section 143(3)Section 92C(3)

section 92C(3) and Rule 10B(3) are satisfied in the present case. 8. That on the facts and circumstances of the case and in law, the Ld. AO/Ld. TPO/DRP has erred in enhancing the income of Appellant by Rs. 2,90,89,437 while holding that the Appellant's international transaction pertaining to provision of Staff 8 Augmentation Service

RAJKAMAL STONE METAL WORKS,AMBEGAON KHURD, DIST. PUNE vs. ACIT CIRCLE 5 PUNE, PUNE

In the result, the appeal filed by the assessee is allowed

ITA 691/PUN/2024[2017-18]Status: DisposedITAT Pune25 Oct 2024AY 2017-18

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2017-18

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Arvind Desai, Addl. CIT DR
Section 142(1)Section 2(47)Section 45Section 47

price by passing necessary journal entries. 5. However, the Assessing Officer was not satisfied with the arguments of the assessee. He noted that the assessee firm and the sister concern has purchased the lands for business purpose. However, as no business was carried on in these lands, the same was transferred to the partners which amounts to a transfer resulting

ACIT, CENTRAL CIRCLE-1, NASHIK, NASHIK vs. RAJENDRA RASIKLAL SHAH, NASHIK

In the result, the appeal of the Revenue is dismissed

ITA 1015/PUN/2024[2013-14]Status: DisposedITAT Pune20 Mar 2025AY 2013-14

Bench: Dr.Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita No.1015/Pun/2024 Assessment Year : 2013-14

For Appellant: Shri Sanket JoshiFor Respondent: Shri Ajay Kumar Keshari
Section 143(3)Section 147Section 148Section 250Section 53Section 54

price, the assessee had given up or 13 Rajendra Rasiklal Shah relinquished his right of specific performance and as consideration of relinquishing that right, the assessee was paid a sum of Rs. 6,00,000/-. The right, title and interest acquired under the agreement of sale clearly fall within the definition of capital asset (Section 2(14)). Instead of assigning

KRISH WINES,JALGAON vs. ACIT CIRCLE 1,, JALGAON

In the result, the appeal filed by the assessee is dismissed

ITA 2098/PUN/2024[2017-18]Status: DisposedITAT Pune27 Oct 2025AY 2017-18
Section 142(1)Section 143(2)Section 145Section 69A

section 145 of the Act and\nestimated the GP rate @ 10% by observing as under:\n“8.14 As already mentioned, the assessee was requested to furnish details of\nsales, purchases, gross profits, etc separately for country liquor and IMFL/Beer.\nIn spite of sufficient opportunity given, the assessee did not furnish the same,\nwhich is surprising. There seems to be absolutely

ASSISTANT COMMISSIONER OF INCOME TAX, KOLHAPUR vs. NATHMAL RUPCHAND JAIN, KOLHAPUR

In the result, the appeal filed by the Revenue is dismissed

ITA 1295/PUN/2024[2020-21]Status: DisposedITAT Pune27 Jan 2025AY 2020-21

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2020-21

For Appellant: Shri Suhas P BoraFor Respondent: Shri Amol Khairnar CIT-DR
Section 132Section 133(6)Section 143(2)Section 145(3)Section 69A

transferring the money through hawala to persons in Delhi also does not seem plausible. The cash was deposited in months of April and May while the purchase from M/s Rishabh Trading Company was done in October and moreover why would an assessee first show bogus sales and then to offset the same undertake bogus purchases and generate cash for making

BAJAJ HOUSING FINANCE LIMITED,PUNE vs. ITO, WARD-8(1), PUNE, PUNE

In the result, the appeal filed by the assessee is allowed

ITA 1608/PUN/2025[2017-18]Status: DisposedITAT Pune09 Oct 2025AY 2017-18

Bench: Dr.Manish Borad

For Respondent: Appellant by Shri Nikhil Mutha
Section 143(1)Section 250Section 250(6)Section 270ASection 270A(9)

145 taxmann.com 665 (Delhi HC) [28-03-2022) 6. On the other hand, Ld. Departmental Representative vehemently argued supporting the order of ld.CIT(A). 7. I have heard the rival contentions and perused the record placed before me. I observe that the assessee is a Limited Company and engaged in the business of providing housing loans to Developers

INCOME TAX OFFICER WARD HINGOLI, WARD HINGOLI (CAMP AT PARBHANI) vs. VISHWAS AGRO PRODUCT PVT LTD, PARBHANI

In the result, the appeal filed by the Revenue is allowed for statistical purposes

ITA 1566/PUN/2024[2017-18]Status: DisposedITAT Pune29 May 2025AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2017-18

For Appellant: Shri Govind PrasadFor Respondent: Shri Milind Debaje – JCIT (Virtual)
Section 143(2)

transferred for investment in fixed assets. Hence it is hereby concluded that the funds received by the assessee-company from the Pranav International Ltd., Dubai to the tune of Rs.1,62,84,153/- in FY 2016-17 are unexplained credit in the books of the assessee. Accordingly, the unexplained credit of Rs.1,62,84,153/- is added to the total

ASSTT. COMMISSIONER OF INCOME-TAX, CIRCLE-5, PUNE, PUNE vs. SANGAM PRESS PRIVATE LIMITED , PUNE

Appeal is dismissed

ITA 674/PUN/2024[2017-18]Status: DisposedITAT Pune25 Oct 2024AY 2017-18

Bench: Shri R. K. Panda & Shri Satbeer Singh Godaraआयकर अपील सं. / Ita No.674/Pun/2024 िनधा"रण वष" / Assessment Year: 2017-18 Acit, Circle-5, Pune. Vs. Sangam Press Private Limited, 17-B, Sangam House, Sangam Press Road, Pune- 411038. Pan : Aaccs5995B Appellant Respondent Revenue By : Shri Ajay Kumar Keshari Assessee By Shri C. H. Naniwadekar : Date Of Hearing : 10.09.2024 Date Of Pronouncement : 25.10.2024 आदेश / Order Per Satbeer Singh Godara, Jm: This Revenue’S Appeal For Assessment Year 2017-18 Arises Against The Commissioner Of Income Tax (Appeals)-12, [In Short The “Cit(A)”] Pune’S Din & Order No.Itba/Apl/S/250/2023- 24/1060642739(1), Dated 08.02.2024, In Proceedings U/S 143(3) Of The Income Tax Act, 1961 (In Short “The Act”). Heard Both The Parties. Case File Perused.

For Respondent: Shri Ajay Kumar Keshari
Section 143(3)Section 43C

price or all significant risks and rewards of ownership have been transferred to the buyer and the seller retains no effective control of the goods transferred to a degree usually associated with ownership; and (it) no significant uncertainty exists regarding the amount of the consideration that will be derived from the sale of the goods." The Expert Advisory Committee

PUNE MATHADI HAMAL AND OTHER MANUAL WORKERS BOARD,PUNE vs. INCOME TAX OFFICER, WARD-5(1), PUNE, PUNE

In the result, appeal of the assessee is partly allowed

ITA 1012/PUN/2023[2018-19]Status: DisposedITAT Pune27 Jun 2024AY 2018-19

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.1012/Pun/2023 िनधा"रण वष" / Assessment Year : 2018-19 Pune Mathadihamal & Other The Income Tax Manual Workers Board, V Officer, Shramashakti Bhavan, S Ward-5(1), Pune. Coomercial Plot No.1, Market Yard, Pune – 411037. Pan: Aaalp0097L Appellant/ Assessee Respondent /Revenue Assessee By Shri Vipul Joshi – Ar Revenue By Shri Ajay Kumar Keshari & Shri Rajesh Gawali– Dr’S Date Of Hearing 17/04/2024 Date Of Pronouncement 27/06/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Orders Of Ld.Commissionerof Income Tax(Appeals)[Nfac], Under Section 250 Of The Act Dated 14.07.2023 :

For Appellant: 2. The ld.AR submitted written submissions, relevant part of the same is reprodu
Section 11Section 12ASection 143(3)Section 250

145 taxmann.com 278 (Amritsar - Trib.)] (iii) Alpha Educational Trust v. DCIT (Exemption) - [2023] 150 taxmann.com 20 (Chennai - Trib.) III. Proposition 3: If an Application for Registration is not disposed off within 6 months, then same isdeemed to be accepted/approved, in terms of section 12AA(2). Sardari Lai Oberoi memorial Charitable Trust v. ITO [2005] 3 SOT 229 (Delhi)] SambandhOrganisation

SMT. SUMANDEVI DINESHKUMAR TULSYAN,,NASHIK vs. INCOME-TAX OFFICER, WARD - 1(5),, NASHIK

ITA 814/PUN/2018[2014-15]Status: DisposedITAT Pune28 Nov 2025AY 2014-15
Section 10(38)Section 133ASection 142(1)Section 143(2)Section 144A

145/- in the hands of his wife on account of bogus Long Term Capital\nGains for assessment year 2014-15. However, vide letter dated 04.09.2015 the\nassessee retracted from his earlier statement. It was contended that the long term\ncapital gains are genuine and correct and legitimate deduction has been claimed u/s\n10(38) on the purchase/sale of shares

DINESHKUMAR RAMCHANDRA TULSYAN (HUF),,NASHIK vs. INCOME-TAX OFFICER, WARD - 1(5),, NASHIK

In the result, both the appeals filed by the assessee are partly allowed

ITA 813/PUN/2018[2014-15]Status: DisposedITAT Pune28 Nov 2025AY 2014-15

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2014-15 Dineshkumar Ramchandra Tulsyan (Huf) Ito, Ward 1(5), 214B, Laxmi Niwas, Mahatma Nagar, Vs. Nashik Nashik – 422007 Pan: Aachd5953R (Appellant) (Respondent) Assessment Year : 2014-15 Smt. Sumandevi Dineshkumar Tulsyan Ito, Ward 1(5), 214B, Laxmi Niwas, Mahatma Nagar, Vs. Nashik Nashik – 422007 Pan: Ackpt1322Q (Appellant) (Respondent)

For Appellant: Shri Pramod S ShingteFor Respondent: Shri Rajesh Haladkar (through virtual)
Section 10(38)Section 133ASection 142(1)Section 143(2)Section 144A

transferred to D-mat account on 28.12.2012 and sold through IIFL and the amount of Rs.1,01,12,902/- received in lieu of sale consideration was deposited in ICICI Bank. The Assessing Officer sought directions from the JCIT u/s 144A of the Act vide letter dated 26.12.2016 who gave directions which have been reproduced by the Assessing Officer

ASHWINI SAHAKARI RUNGNALAYA & RESEARCH CENTER,,SOLAPUR vs. COMMISSIONER OF INCOME-TAX, (EXEMPTIONS),, PUNE

ITA 714/PUN/2018[N.A]Status: DisposedITAT Pune07 Mar 2024

Bench: Hon’Ble Shri S. S. Viswanethra Ravi & Shri G. D. Padmahshaliआयकर अपील सं. / Ita No. 714/Pun/2018 Ashwini Sahakari Rugnalaya & Research Centre 7107/1, Plot No. 180, North Sadar Bazar, Solapur-413003. Pan: Aaaja0041K . . . . . . . अपीलार्थी / Appellant

For Appellant: Mr Pramod Shingte [‘Ld. AR’]For Respondent: Mr Keyur Patel [‘Ld. DR’]
Section 10Section 10(23)Section 11Section 12ASection 22Section 253(1)(c)

transferred to Ld. CIT(E) jurisdiction. The Ld. CIT(E) vide notice dt. 24/03/2017 revived former cancellation proceedings and before culmination had granted reasonable opportunities to enable the assessee to rebut Revenue’s negative observations/findings. After analysis of facts with an elaborate discussion laid in para 4, the Ld. CIT(E) by the impugned order dt.28/03/2018 has finally withdrawn/cancelled

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 544/PUN/2016[2004-05]Status: DisposedITAT Pune30 Sept 2025AY 2004-05

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

section 43B of the Act. He similarly noted that the assessee had also made payment of Rs.6.40 crores to LIC on account of employees’ gratuity fund from the date of its incorporation till 31.03.2003 whereas the expenses for the year was only Rs.1.10 crores. Thus the assessee has made additional claim of Rs.5.30crores. According to the Assessing Officer since

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 1155/MUM/2016[2004-05]Status: DisposedITAT Pune30 Sept 2025AY 2004-05

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

section 43B of the Act. He similarly noted that the assessee had also made payment of Rs.6.40 crores to LIC on account of employees’ gratuity fund from the date of its incorporation till 31.03.2003 whereas the expenses for the year was only Rs.1.10 crores. Thus the assessee has made additional claim of Rs.5.30crores. According to the Assessing Officer since

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 545/PUN/2016[2005-06]Status: DisposedITAT Pune30 Sept 2025AY 2005-06

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

section 43B of the Act. He similarly noted that the assessee had also made payment of Rs.6.40 crores to LIC on account of employees’ gratuity fund from the date of its incorporation till 31.03.2003 whereas the expenses for the year was only Rs.1.10 crores. Thus the assessee has made additional claim of Rs.5.30crores. According to the Assessing Officer since

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 1154/MUM/2016[2005-06]Status: DisposedITAT Pune30 Sept 2025AY 2005-06

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

section 43B of the Act. He similarly noted that the assessee had also made payment of Rs.6.40 crores to LIC on account of employees’ gratuity fund from the date of its incorporation till 31.03.2003 whereas the expenses for the year was only Rs.1.10 crores. Thus the assessee has made additional claim of Rs.5.30crores. According to the Assessing Officer since

DEPUTY COMMISSIONER OF INCOME-TAX vs. THE JAWAHARLAL NEHRU PORT TRUST,, RAIGAD

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 543/PUN/2016[2003-04]Status: DisposedITAT Pune30 Sept 2025AY 2003-04

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

section 43B of the Act. He similarly noted that the assessee had also made payment of Rs.6.40 crores to LIC on account of employees’ gratuity fund from the date of its incorporation till 31.03.2003 whereas the expenses for the year was only Rs.1.10 crores. Thus the assessee has made additional claim of Rs.5.30crores. According to the Assessing Officer since

JAWAHAR LAL NEHRU PORT TRUST,NAVI MUMBAI vs. ACIT PANVEL, PANVEL

In the result, all the three appeals filed by the Revenue are dismissed and all the three appeals filed by the assessee are partly allowed

ITA 1153/MUM/2016[2003-04]Status: DisposedITAT Pune30 Sept 2025AY 2003-04

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Madhur Agrawal, AdvocateFor Respondent: S/Shri Sham Walve, Special Counsel along with Tanzil Padvekar and Bhavik Chheda
Section 10(20)Section 11Section 12ASection 142Section 143(1)Section 143(3)Section 263

section 43B of the Act. He similarly noted that the assessee had also made payment of Rs.6.40 crores to LIC on account of employees’ gratuity fund from the date of its incorporation till 31.03.2003 whereas the expenses for the year was only Rs.1.10 crores. Thus the assessee has made additional claim of Rs.5.30crores. According to the Assessing Officer since