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8 results for “transfer pricing”+ Section 269clear

Sorted by relevance

Mumbai155Delhi110Hyderabad57Jaipur26Chennai13Bangalore13Indore11Cuttack9Ahmedabad8Pune8Kolkata5SC3Cochin3Jodhpur2Chandigarh2Visakhapatnam2

Key Topics

Section 143(3)12Section 143(2)6Section 143(1)(a)6Transfer Pricing5Addition to Income5Section 92C4Section 14A4Section 2634Deduction4

REHAU POLYMERS PVT.LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 8,, PUNE

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

ITA 658/PUN/2022[2018-19]Status: DisposedITAT Pune04 Mar 2025AY 2018-19
Section 143(2)Section 143(3)

269 (Bom)], he submitted that\nthe Hon'ble High Court in the said decision has held that the action of the TPO in\ndetermination of ALP without following any of the prescribed methods is incorrect\nand the addition made is to be deleted on the said reason.\n15. Referring to the decision of the Hon'ble Bombay High Court

DCIT, SWARGATE PUNE vs. CUMMINS INDIA LTD , PUNE

In the result, appeal of the assessee bearing ITA No

ITA 1256/PUN/2023[2018-19]Status: DisposedITAT Pune04 Dec 2025AY 2018-19
Section 115J
Disallowance4
Section 143(1)3
Section 403
Section 143(1)
Section 143(1)(a)
Section 143(2)
Section 143(3)
Section 144C(5)
Section 14A
Section 250
Section 80J
Section 92C

pricing report obtained and the transfer\npricing documentation maintained.”\n13. On going through the judgment of Hon'ble Jurisdictional\nHigh Court and applying the ratio laid down therein on the\nfacts of the present case, we find that the same are squarely\napplicable and, therefore, we hold that 1d. DRP's directions\nconfirming the action of TPO making the upward

CUMMINS INDIA LIMITED,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 1(1),, PUNE

In the result, appeal of the assessee bearing ITA No

ITA 632/PUN/2022[2018-19]Status: DisposedITAT Pune04 Dec 2025AY 2018-19
Section 115JSection 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 144C(5)Section 14ASection 250Section 80JSection 92C

pricing report obtained and the transfer\npricing documentation maintained.”\n\n13. On going through the judgment of Hon'ble Jurisdictional\nHigh Court and applying the ratio laid down therein on the\nfacts of the present case, we find that the same are squarely\napplicable and, therefore, we hold that 1d. DRP's directions\n\nconfirming the action of TPO making

DCIT, CIRCLE 8 PUNE, PUNE vs. ALFA LAVAL INDIA PVT LTD, PUNE

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

ITA 2270/PUN/2024[2018-19]Status: DisposedITAT Pune10 Oct 2025AY 2018-19
Section 143(1)Section 143(2)Section 143(3)Section 14ASection 36(1)(va)Section 40Section 92C

transfer pricing proceedings, the TPO observed that the assessee had\nentered into various international transactions with its AEs. He observed that the\nassessee company has adopted TNMM Method for benchmarking the international\ntransaction of export of traded spares to the AEs. Further, the assessee company\nhas selected 6 companies as comparable for trading activity. From the submissions\nfiled

LIQUIDHUB ANALYTICS PVT. LTD. (NOW MERGED WITH CAPGEMINI TECHNOLOGY SERVICES INDIA LTD),PUNE vs. NFAC, PUNE

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

ITA 1952/PUN/2024[2020-21]Status: DisposedITAT Pune25 Mar 2025AY 2020-21

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2020-21

For Appellant: Shri Nikhil PathakFor Respondent: Smt Nilu Jaggi, CIT
Section 143Section 143(3)Section 144C(1)

269 under section 37 of the Act on account of interest for late payment of PF and GST, without appreciating that the same are compensatory in nature 12. Without prejudice to the above, Ld. AD, in pursuance to the directions of the Hon'ble DRP, grossly erred in not allowing additional deduction under section 10AA

YASHWANTRAO CHAVAN MAHARASHTRA OPEN UNIVERSITY,NASHIK vs. COMMISSIONER OF INCOME TAX,-EXEMPTION, PUNE, PUNE

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

ITA 1386/PUN/2025[2021-22]Status: DisposedITAT Pune11 Aug 2025AY 2021-22

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Sharad A. ShahFor Respondent: Shri Amit Bobde
Section 11Section 143(2)Section 143(3)Section 263

Transfer Pricing Officer, as the case may be, had been the subject matter of any appeal filed on or before or after the 1st day of June, 1988, the powers of the Principal Commissioner or Commissioner under this sub-section shall extend and shall be deemed always to have extended to such matters as had not been considered and decided

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

269 (Raipur - Trib.) (ii) Dera Baba Bhai Gurdas Ji Udasin Trust (Regd) (Mansa) v. ITO [(2022) 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

ACIT CIRCLE-12, PUNE, PUNE vs. DHIRAJ BHAUSAHEB NIKAM, PUNE

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

ITA 1375/PUN/2025[2014-15]Status: DisposedITAT Pune11 Feb 2026AY 2014-15

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2014-15 Acit, Circle – 12, Pune Dhiraj Bhausaheb Nikam Vs. 515/516, Purva Plaza, Sadashiv Peth, Pune – 411030 Pan: Aahpn5137C (Appellant) (Respondent) Assessee By : None Department By : Shri Deepak Kumar Kedia, Jcit (Through Virtual) Date Of Hearing : 10-02-2026 Date Of Pronouncement : 11-02-2026 O R D E R Per R.K. Panda, Vp:

For Appellant: NoneFor Respondent: Shri Deepak Kumar Kedia, JCIT
Section 10(38)Section 142(1)Section 143(2)Section 2(47)

269/- after claiming deduction of Rs.40,43,305/- as exempt u/s 10(38) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) being the long term capital gain on sale of listed shares. The case of the assessee was selected for scrutiny through CASS and accordingly statutory notice u/s 143(2) of the Act was issued