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102 results for “transfer pricing”+ Section 40A(3)clear

Sorted by relevance

Delhi466Mumbai417Bangalore155Ahmedabad115Chennai115Pune102Kolkata93Jaipur48Hyderabad29Surat27Cochin26Raipur24Indore22Visakhapatnam17Chandigarh17Jodhpur12Cuttack10Rajkot9Agra5Karnataka5Guwahati4Calcutta3Amritsar3Lucknow2Nagpur2SC2Allahabad1

Key Topics

Addition to Income65Section 12A36Section 14A35Section 37(1)35Deduction34Section 143(3)31Section 10(20)24Section 1124Section 92B20Section 40A(2)(a)

UTTAM ENERGY LIMITED,PUNE vs. ACIT CIRCLE-12, PUNE

Appeal of the Assessee is partly allowed

ITA 2033/PUN/2019[2015-16]Status: DisposedITAT Pune30 May 2024AY 2015-16

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2033/Pun/2019 िनधा"रण वष" / Assessment Year: 2015-16 Uttam Energy Limited, The Acit, Circle-12, Mahendra Chamber, Mayfair V Pune. Co-Op Housing Society, S A-4, Dhole Patil Road, Pune – 411001. Pan: Aabcu4100H Appellant/ Revenue Respondent /Assessee Assessee By Shri Ch Naniwadekar & Kiran Sanmane – Ar;S Revenue By Shri Deepak Garg – Cit Date Of Hearing 16/05/2024 Date Of Pronouncement 30/05/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Has Been Filed By The Assessee Against The Final Assessment Order Of The Learned Acit, Circle-12, Pune Passed U/Sec. 143(3) R.W.S. 144C(13) Of The Of The Income Tax Act, 1961 (In Short "The Act") After Giving Effect To The Learned Drp’S Order Dated 24.09.2019. 1.1 The Assessee Has Raised The Following Grounds Of Appeal :

Section 143(3)Section 153Section 153(1)Section 40A(2)(b)Section 92BSection 92C

40A(2)(b) is not a specified domestic transaction under section 92BA of the IT Act. 2. Without prejudice to the Ground No.1, the reference to the TPO under section 92CA (1) by the Learned Assessing Officer is in defiance to Instruction Nos. 15 of 2015, 3 of 2016 and against the principles of natural justice

Showing 1–20 of 102 · Page 1 of 6

19
Disallowance17
Transfer Pricing12

DANA INDIA PVT.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(2),, PUNE

In the result, the appeal is partly allowed

ITA 473/PUN/2018[2013-14]Status: DisposedITAT Pune25 Feb 2021AY 2013-14

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.473/Pun/2018 िनधा"रण वष" / Assessment Year : 2013-14

Section 143(3)Section 92C

transfer pricing addition by the AO in the impugned order. 17.3. We have heard the rival submissions and gone through the relevant material on record. It is seen that the assessee claimed to have incurred Rs.11.71 crore to Dana Corporation, USA for receipt of Sales, General and Administration services. The TPO determined Nil ALP primarily on the ground that

ADIENT INDIA PVT.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(1),, PUNE

In the result, the appeal is allowed for statistical purposes

ITA 2986/PUN/2017[2013-14]Status: DisposedITAT Pune31 May 2021AY 2013-14

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Raviनिर्धारण वषा / Assessment Year : 2013-14 Adient India Private Limited Vs. Dcit, Plot No.1, S No.235 & 245, Circle-1(1), Pune Hinjewadi, Tal-Mulshi, Pune - 411057 Pan : Aaact6342D Appellant Respondent Assessee By Shri Dhanesh Bafna Revenue By S/Shri Kalika Singh & Madhavan A.M. Krishnan Date Of Hearing 27-05-2021 Date Of Pronouncement 31-05-2021 आदेश / Order Per R.S.Syal, Vp : This Appeal By The Assessee Is Directed Against The Final Assessment Order Dated 27-10-2017 Passed By The Assessing Officer (Ao) U/S.143(3) Read With Section 144C(13) Of The Income-Tax Act, 1961 (Hereinafter Also Called ‗The Act‘) In Relation To The Assessment Year 2013-14. 2. The Only Issue Raised In This Appeal Is Against Transfer Pricing Addition Of Rs.5,95,39,429. Succinctly, The Factual Matrix Of The Case Is That The Assessee Was Earlier A 50:50 Joint

Section 143(3)Section 144C(13)

transfer pricing provisions would be too simplistic an approach leading to laying down a preposterous interpretation of the Chapter-X. 7.5. There is another reason for not accepting the assessee‘s contention of accepting the SDT at ALP on the basis of reasonableness of the expenditure. All the cases relied by the ld. AR are the transactions between TACO

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 8, PUNE vs. SPICER INDIA PVT. LTD, PUNE

In the result, the appeal of Revenue is dismissed

ITA 580/PUN/2020[2015-16]Status: DisposedITAT Pune03 Jun 2021AY 2015-16

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

For Appellant: Shri R.D. OnkarFor Respondent: Shri Kalika Singh
Section 37Section 37(1)Section 40A(2)(b)Section 92C

40A(2) is only applicable to expenditure, transfer pricing provisions are applicable to both income and expenditure. He argued that the CIT(A) erred in relying the decision rendered by the ITAT on deductibility of expenses u/s. 37 of the Act in the context of section 92 of the Act. 7. Further, he referred to the decision of ITAT Bangalore

YAZAKI INDIA P LTD., (FORMERLY KNOWN AS YAZAKI (I) LTD.,),PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX,, PUNE

In the result, the appeal is partly allowed

ITA 621/PUN/2014[2009-10]Status: DisposedITAT Pune11 Jul 2019AY 2009-10

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.621/Pun/2014 िनधा"रण वष" / Assessment Year : 2009-10

Section 143(3)Section 40A(2)(a)

40A(2)(a) of the Act. Ergo, we order to delete the addition of Rs.2,96,50,650/- made on this score. This ground is allowed. 10 Yazaki India Private Limited 9. The next issue concerns the transfer pricing addition made by the Assessing Officer. Facts apropos this issue are that the assessee furnished report in Form 3CEB indicating

INCOME TAX OFFICER , JALNA vs. VIKRAM TEA PROCESSOR PRIVATE LIMITED , JALNA

In the result, both the appeals filed by the Revenue are dismissed

ITA 685/PUN/2025[2013]Status: DisposedITAT Pune26 Sept 2025

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2013-14

For Appellant: Shri J P BairagraFor Respondent: Shri Basavaraj Hiremeth, Addl CIT
Section 143(2)Section 40A(2)(a)Section 92A(2)(a)Section 92BSection 92C

Transfer Pricing Officer (TPO) to determine the Arm’s Length Price (ALP) of the transactions entered with AEs. From the various details furnished by the assessee the TPO noted that the assessee has entered into following specified domestic transactions during the year: Sr. No. Name of AEs Description of Specific Amount (In Method domestic transactions INR) 1 ASSAM TEA PURCHASE

INCOME TAX OFFICER WARD 1 JALNA, JALNA vs. VIKRAM TEA PROCESSOR PRIVATE LIMITED, JALNA

In the result, both the appeals filed by the Revenue are dismissed

ITA 2285/PUN/2024[2013]Status: DisposedITAT Pune26 Sept 2025

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2013-14

For Appellant: Shri J P BairagraFor Respondent: Shri Basavaraj Hiremeth, Addl CIT
Section 143(2)Section 40A(2)(a)Section 92A(2)(a)Section 92BSection 92C

Transfer Pricing Officer (TPO) to determine the Arm’s Length Price (ALP) of the transactions entered with AEs. From the various details furnished by the assessee the TPO noted that the assessee has entered into following specified domestic transactions during the year: Sr. No. Name of AEs Description of Specific Amount (In Method domestic transactions INR) 1 ASSAM TEA PURCHASE

DEPUTY COMMISSIONER OF INCOME-TAX vs. M/S. RAJMAL LAKHICHAND,,

In the result, appeal of the Department is dismissed

ITA 832/PUN/2015[2010-11]Status: DisposedITAT Pune28 Feb 2018AY 2010-11

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

For Appellant: Shri Sunil PathakFor Respondent: Shri Rajeev Kumar
Section 143(2)Section 14ASection 2(22)(e)Section 36(1)(iii)Section 40A(2)(a)

3 raised in appeal by the assessee relating to GP addition and ground No. 1 raised in appeal by the Department assailing deleting of addition u/s.40A(2) of the Act and substituting the addition on estimated GP by Commissioner of Income Tax(Appeal) are taken up together for adjudication. During the course of scrutiny assessment proceedings, the Assessing Officer made

M/S. RAJMAL LAKHICHAND vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeal of the Department is dismissed

ITA 670/PUN/2015[2010-11]Status: DisposedITAT Pune28 Feb 2018AY 2010-11

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

For Appellant: Shri Sunil PathakFor Respondent: Shri Rajeev Kumar
Section 143(2)Section 14ASection 2(22)(e)Section 36(1)(iii)Section 40A(2)(a)

3 raised in appeal by the assessee relating to GP addition and ground No. 1 raised in appeal by the Department assailing deleting of addition u/s.40A(2) of the Act and substituting the addition on estimated GP by Commissioner of Income Tax(Appeal) are taken up together for adjudication. During the course of scrutiny assessment proceedings, the Assessing Officer made

SHRI BHOGAWATI SAH. SAKHAR KARKHANA LTD,,KOLHAPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX,, KOLHAPUR

In the result, the appeals of assessees are allowed for statistical purposes

ITA 992/PUN/2017[2010-11]Status: DisposedITAT Pune20 Nov 2019AY 2010-11

Bench: Shri Anil Chaturvedi & Shri S.S. Viswanethra Ravisl.

Section 37(1)

section 40A(2) of the Act, as has been held by the Hon‟ble Supreme Court supra. Needless to say, the assessee will be allowed a reasonable opportunity of hearing by the AO in such fresh determination of the issue.” 3. In view of the above, the issue involving excess cane price in all the respective assessees remanded

JAWAHAR SHETKARI SSK LTD,,KOLHAPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX,, ICHALKARANJI

In the result, the appeals of assessees are allowed for statistical purposes

ITA 822/PUN/2017[2000-01]Status: DisposedITAT Pune20 Nov 2019AY 2000-01

Bench: Shri Anil Chaturvedi & Shri S.S. Viswanethra Ravisl.

Section 37(1)

section 40A(2) of the Act, as has been held by the Hon‟ble Supreme Court supra. Needless to say, the assessee will be allowed a reasonable opportunity of hearing by the AO in such fresh determination of the issue.” 3. In view of the above, the issue involving excess cane price in all the respective assessees remanded

SHRI CHH. SHAHU SAHAKARI SAKHAR KARKHANA LTD,,KOLHAPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX,, KOLHAPUR

In the result, the appeals of assessees are allowed for statistical purposes

ITA 856/PUN/2017[2011-12]Status: DisposedITAT Pune20 Nov 2019AY 2011-12

Bench: Shri Anil Chaturvedi & Shri S.S. Viswanethra Ravisl.

Section 37(1)

section 40A(2) of the Act, as has been held by the Hon‟ble Supreme Court supra. Needless to say, the assessee will be allowed a reasonable opportunity of hearing by the AO in such fresh determination of the issue.” 3. In view of the above, the issue involving excess cane price in all the respective assessees remanded

SHRI CHH. SHAHU SAHAKARI SAKHAR KARKHANA LTD,,KOLHAPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX,, KOLHAPUR

In the result, the appeals of assessees are allowed for statistical purposes

ITA 858/PUN/2017[2013-14]Status: DisposedITAT Pune20 Nov 2019AY 2013-14

Bench: Shri Anil Chaturvedi & Shri S.S. Viswanethra Ravisl.

Section 37(1)

section 40A(2) of the Act, as has been held by the Hon‟ble Supreme Court supra. Needless to say, the assessee will be allowed a reasonable opportunity of hearing by the AO in such fresh determination of the issue.” 3. In view of the above, the issue involving excess cane price in all the respective assessees remanded

JAWAHAR SHETKARI SSK LTD.,,KOLHAPUR vs. ASSISTANT COMMISSIONER OF INCOME-TAX,, ICHALKARANJI

In the result, the appeals of assessees are allowed for statistical purposes

ITA 825/PUN/2017[2012-13]Status: DisposedITAT Pune20 Nov 2019AY 2012-13

Bench: Shri Anil Chaturvedi & Shri S.S. Viswanethra Ravisl.

Section 37(1)

section 40A(2) of the Act, as has been held by the Hon‟ble Supreme Court supra. Needless to say, the assessee will be allowed a reasonable opportunity of hearing by the AO in such fresh determination of the issue.” 3. In view of the above, the issue involving excess cane price in all the respective assessees remanded

SHRI BHOGAWATI SAH. SAKHAR KARKHANA LTD,,KOLHAPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX,, KOLHAPUR

In the result, the appeals of assessees are allowed for statistical purposes

ITA 994/PUN/2017[2012-13]Status: DisposedITAT Pune20 Nov 2019AY 2012-13

Bench: Shri Anil Chaturvedi & Shri S.S. Viswanethra Ravisl.

Section 37(1)

section 40A(2) of the Act, as has been held by the Hon‟ble Supreme Court supra. Needless to say, the assessee will be allowed a reasonable opportunity of hearing by the AO in such fresh determination of the issue.” 3. In view of the above, the issue involving excess cane price in all the respective assessees remanded

APPASAHEB NALAWADE GADHINGLAJ TALUKA SSK LTD.,,KOLHAPUR vs. DEPUTY COMMISSIONER OF INCOME TAX,, KOLHAPUR

In the result, the appeals of assessees are allowed for statistical purposes

ITA 1046/PUN/2017[2012-13]Status: DisposedITAT Pune20 Nov 2019AY 2012-13

Bench: Shri Anil Chaturvedi & Shri S.S. Viswanethra Ravisl.

Section 37(1)

section 40A(2) of the Act, as has been held by the Hon‟ble Supreme Court supra. Needless to say, the assessee will be allowed a reasonable opportunity of hearing by the AO in such fresh determination of the issue.” 3. In view of the above, the issue involving excess cane price in all the respective assessees remanded

APPASAHEB NALAWADE GADHINGLAJ TALUKA SSK LTD.,,KOLHAPUR vs. DEPUTY COMMISSIONER OF INCOME TAX,, KOLHAPUR

In the result, the appeals of assessees are allowed for statistical purposes

ITA 1044/PUN/2017[2010-11]Status: DisposedITAT Pune20 Nov 2019AY 2010-11

Bench: Shri Anil Chaturvedi & Shri S.S. Viswanethra Ravisl.

Section 37(1)

section 40A(2) of the Act, as has been held by the Hon‟ble Supreme Court supra. Needless to say, the assessee will be allowed a reasonable opportunity of hearing by the AO in such fresh determination of the issue.” 3. In view of the above, the issue involving excess cane price in all the respective assessees remanded

KUMBHI KASARI SAHAKARI SAKHAR KARKHANA LTD,,KOLHAPUR vs. ASSISTANT COMMISSIONER OF INCOME-TAX,, KOLHAPUR

In the result, the appeals of assessees are allowed for statistical purposes

ITA 718/PUN/2017[2012-13]Status: DisposedITAT Pune20 Nov 2019AY 2012-13

Bench: Shri Anil Chaturvedi & Shri S.S. Viswanethra Ravisl.

Section 37(1)

section 40A(2) of the Act, as has been held by the Hon‟ble Supreme Court supra. Needless to say, the assessee will be allowed a reasonable opportunity of hearing by the AO in such fresh determination of the issue.” 3. In view of the above, the issue involving excess cane price in all the respective assessees remanded

MANGANGA SAHAKARI SAKHAR KARKHANA LTD,,SANGLI vs. ASSISTANT COMMISSIONER OF INCOME TAX,, SANGLI

In the result, the appeals of assessees are allowed for statistical purposes

ITA 603/PUN/2017[2011-12]Status: DisposedITAT Pune20 Nov 2019AY 2011-12

Bench: Shri Anil Chaturvedi & Shri S.S. Viswanethra Ravisl.

Section 37(1)

section 40A(2) of the Act, as has been held by the Hon‟ble Supreme Court supra. Needless to say, the assessee will be allowed a reasonable opportunity of hearing by the AO in such fresh determination of the issue.” 3. In view of the above, the issue involving excess cane price in all the respective assessees remanded

JAWAHAR SHETKARI SSK LTD,,KOLHAPUR vs. ASSISTANT COMMISSIONER OF INCOME-TAX, ICHALKARANJ,, ICHALKARANJI

In the result, the appeals of assessees are allowed for statistical purposes

ITA 2153/PUN/2017[2014-15]Status: DisposedITAT Pune20 Nov 2019AY 2014-15

Bench: Shri Anil Chaturvedi & Shri S.S. Viswanethra Ravisl.

Section 37(1)

section 40A(2) of the Act, as has been held by the Hon‟ble Supreme Court supra. Needless to say, the assessee will be allowed a reasonable opportunity of hearing by the AO in such fresh determination of the issue.” 3. In view of the above, the issue involving excess cane price in all the respective assessees remanded