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20 results for “transfer pricing”+ Section 153(5)clear

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Key Topics

Section 26337Section 172(4)29Section 14724Section 143(3)16Section 10(38)10Section 144C10Addition to Income10Penny Stock5Section 172(3)

ISS SHIPPING INDIA PVT. LTD., (AS AGENT FOR MAERSK TANKERS SINGAPORE PTE. LTD., SINGAPORE),NAVI MUMBAI vs. DY. COMMR. OF INCOME TAX ( INTERNATIONAL TAXATION),, RAJKOT

In the result, both the appeals of the assessee are allowed for statistical purposes

ITA 429/RJT/2018[2017-18]Status: DisposedITAT Rajkot21 Nov 2019AY 2017-18
For Appellant: Shri Porus Kaka, A.RFor Respondent: Shri Jitendra Kumar, CIT-D.R
Section 172(3)Section 172(4)

153 or section 153B, pass the assessment order under sub-section (3) within one month from the end of the month in which,— (a) the acceptance is received; or (b) the period of filing of objections under sub-section (2) expires. (5) The Dispute Resolution Panel shall, in a case where any objection is received under sub- section (2), issue

ISS SHIPPING INDIA PVT. LTD., (AS AGENT FOR MAERSK TANKERS SINGAPORE PTE. LTD., SINGAPORE),NAVI MUMBAI vs. DY. COMMR. OF INCOME TAX ( INTERNATIONAL TAXATION),, RAJKOT

4
Section 2504
Survey u/s 133A4
Exemption3

In the result, both the appeals of the assessee are allowed for statistical purposes

ITA 430/RJT/2018[2017-18]Status: DisposedITAT Rajkot21 Nov 2019AY 2017-18
For Appellant: Shri Porus Kaka, A.RFor Respondent: Shri Jitendra Kumar, CIT-D.R
Section 172(3)Section 172(4)

153 or section 153B, pass the assessment order under sub-section (3) within one month from the end of the month in which,— (a) the acceptance is received; or (b) the period of filing of objections under sub-section (2) expires. (5) The Dispute Resolution Panel shall, in a case where any objection is received under sub- section (2), issue

LR2 MANAGEMENT K/S AGENT OF PRINCIPAL FREIGHT BENEFICIARY, INTEROCEAN SHIPPING (I) PVT. LTD.,,JAMNAGAR vs. THE INCOME TAX OFFICER, (INTER. TAXA.),, RAJKOT-GUJARAT

In the result, the appeals are allowed for statistical purposes

ITA 276/RJT/2015[2013-14]Status: DisposedITAT Rajkot09 Aug 2018AY 2013-14
Section 143(1)Section 143(3)Section 144CSection 144C(1)Section 147Section 172(4)

153 or section 153B, pass the assessment order under sub-section (3) within one month from the end of the month in which,— (a) the acceptance is received; or (b) the period of filing of objections under sub-section (2) expires. (5) The Dispute Resolution Panel shall, in a case where any objection is received under sub-section (2), issue

HANDYTANKERS K/S AGENT OF F.B. MAERSK TANKERS C/O ATLANTIC SHIPPING PVT. LTD.,,SIKKA vs. THE DY. COMMR. OF INCOME TAX, (INTERNATIONAL TAXATION),, RAJKOT-GUJARAT

In the result, the appeals are allowed for statistical purposes

ITA 91/RJT/2016[2014-15]Status: DisposedITAT Rajkot09 Aug 2018AY 2014-15
Section 143(1)Section 143(3)Section 144CSection 144C(1)Section 147Section 172(4)

153 or section 153B, pass the assessment order under sub-section (3) within one month from the end of the month in which,— (a) the acceptance is received; or (b) the period of filing of objections under sub-section (2) expires. (5) The Dispute Resolution Panel shall, in a case where any objection is received under sub-section (2), issue

LR2 MANAGEMENT K/S (AS FOREIGN COMMR. MANAGER/AGENT OF PRINCIPAL FREIGHT BENEFICIARY, TORM A/S MAERSK TANKERS SINGAPORE P. LTD.,SIKKA vs. THE INCOME TAX OFFICER, INTER. TAXA.,, RAJKOT-GUJARAT

In the result, the appeals are allowed for statistical purposes

ITA 756/RJT/2014[2013-14]Status: DisposedITAT Rajkot09 Aug 2018AY 2013-14
Section 143(1)Section 143(3)Section 144CSection 144C(1)Section 147Section 172(4)

153 or section 153B, pass the assessment order under sub-section (3) within one month from the end of the month in which,— (a) the acceptance is received; or (b) the period of filing of objections under sub-section (2) expires. (5) The Dispute Resolution Panel shall, in a case where any objection is received under sub-section (2), issue

SHREE MEENAWALA CASTING,RAJKOT vs. THE PCIT, RAJKOT-1, RAJKOT, RAJKTO

In the result, the appeal of the assessee is allowed

ITA 158/RJT/2022[2017-18]Status: DisposedITAT Rajkot28 Sept 2022AY 2017-18
For Appellant: Shri Mehul Ranpura, A.RFor Respondent: Shri Aarsi Prasad, CIT-D.R
Section 143(3)Section 263

153 (5) of the Act for reference: “(5) Where effect to an order under section 250 or section 254 or section 260 or section 262 or section 263 or section 264 is to be given by the Assessing Officer [or the Transfer Pricing

M/S. KANDLA ENERGY AND CHEMICALS LTD.,VILLAGE DEVALIYA, TAL. ANJAR(KUTCH) vs. ADD. CIT, GANDHIDHAM RANGE,, GANDHIDHAM(KUTCH)

In the result, the appeal filed by the Assessee is hereby dismissed

ITA 399/RJT/2018[2014-15]Status: DisposedITAT Rajkot15 Sept 2023AY 2014-15

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 143(3)Section 144C(1)Section 144C(2)Section 144C(2)(b)Section 144C(3)Section 40A(2)(b)Section 92CSection 92E

153, pass the assessment order under sub-section (3) within one month from the end of the month in which,- (a) the acceptance is received ; or (b) the period of filing of objections under sub-section (2) expires. (5) The Dispute Resolution Panel shall, in a case where any objection is received under sub-section (2), issue such directions

SHRI BHARATBHUSHAN KISHANLAL GUPTA,GANDHIDHAM vs. THE ITO- INTERNATIONAL TAXATION , GANDHIDHAM

In the result, the appeal is allowed in the terms indicated above

ITA 269/RJT/2019[2017-18]Status: DisposedITAT Rajkot08 May 2025AY 2017-18

Bench: Dr. Arjun Lalsaini. & Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 269/Rjt/2019 (Assessment Year: 2017-18) (Hybrid Hearing) Bharatbhushan Kishanlal Vs. The Income Tax Officer, Gupta, (International Taxation) Prop. Of Aqua Shipping, Suit - Gandhidham – 370210 100, Grain Merchant Association Bldg., 2Nd Floor, Plot No. 297, Wd – 12B, Gandhidham – 370001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afcpg3849N (अपीलाथ"/Assessee) (""यथ"/Respondent)

For Appellant: Shri D.M. Rindani, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld.Sr. DR
Section 144CSection 172Section 172(4)Section 172(5)Section 234ASection 271(1)(c)

153 [or section 153B], pass the assessment order under sub-section (3) within one month from the end of the month in which,- (a) the acceptance is received; or (b) the period of filing of objections under sub-section (2) expires. (5) The Dispute Resolution Panel shall, in a case where any objection is received under sub-section (2), issue

JAYESH KHIMJI KHIMASIYA HUF,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

ITA 6/RJT/2024[2012-13]Status: DisposedITAT Rajkot09 Sept 2025AY 2012-13

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

Section 10(38)Section 147Section 263

section 263 of the Act." ii. On April 28, 2011, the assessee acquired shares of Kyra Landscapes Limited (formerly known as Aricent Infra Limited) via an off-market transaction facilitated by a brokerage firm. No monetary payment was rendered by the assessee towards the acquisition of the shares as the purchase was financed through the credit balance maintained/created with

BHANUBEN MANSUKHLAL KHIMASIYA,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

ITA 5/RJT/2024[2012-13]Status: DisposedITAT Rajkot09 Sept 2025AY 2012-13

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

Section 10(38)Section 147Section 263

section 263 of the Act." ii. On April 28, 2011, the assessee acquired shares of Kyra Landscapes Limited (formerly known as Aricent Infra Limited) via an off-market transaction facilitated by a brokerage firm. No monetary payment was rendered by the assessee towards the acquisition of the shares as the purchase was financed through the credit balance maintained/created with

MANSUKHLAL KHIMJI KHIMASIYA,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

ITA 4/RJT/2024[2013-14]Status: DisposedITAT Rajkot09 Sept 2025AY 2013-14

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

Section 10(38)Section 147Section 263

section 263 of the Act." ii. On April 28, 2011, the assessee acquired shares of Kyra Landscapes Limited (formerly known as Aricent Infra Limited) via an off-market transaction facilitated by a brokerage firm. No monetary payment was rendered by the assessee towards the acquisition of the shares as the purchase was financed through the credit balance maintained/created with

MANSUKHLAL KHIMJI KHIMASIYA HUF,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

ITA 3/RJT/2024[2012-13]Status: DisposedITAT Rajkot09 Sept 2025AY 2012-13

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

Section 10(38)Section 147Section 263

section 263 of the Act." ii. On April 28, 2011, the assessee acquired shares of Kyra Landscapes Limited (formerly known as Aricent Infra Limited) via an off-market transaction facilitated by a brokerage firm. No monetary payment was rendered by the assessee towards the acquisition of the shares as the purchase was financed through the credit balance maintained/created with

HANSA JITENDRA HARIA,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

In the result, the appeal of the assessee is dismissed

ITA 104/RJT/2024[2013-14]Status: DisposedITAT Rajkot20 Jun 2025AY 2013-14

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.104/Rjt/2024 ("नधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Hansa Jitendra Haria Vs. Principal Commissioner Of 2, Oswal Colony, Near Rajendra Income Tax Balkrindagan, Jamnagar, Gujarat Jamnagar 361005. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahph4309L (Assessee) (Respondent)

For Appellant: Shri Dhaval Shah, ARFor Respondent: Shri Sanjay Punglia, CIT. DR
Section 10(38)Section 147Section 263Section 69A

5,28,540/- chargeable to tax has escaped assessment, within the meaning of section 147 of the Act" ITA No. 104/RJT/2024/AY.2013-14 Hansa Jitendra Haria vs. PCIT 16. We note that due to non-availability of documents and evidences, the assessing officer has failed to conduct the minimum enquiry or verification, during the course of assessment of penny stock case

SIX TWENTY REALTY PVT. LTD.,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 785/RJT/2024[2018-19]Status: DisposedITAT Rajkot11 Mar 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 133ASection 143(3)Section 147Section 148Section 250

5. In view of the above and in view of our detailed submission, we strongly object the proposal to make addition of alleged unaccounted income on estimated basis. 6. It is submitted that there are various discrepancies in interpretation of content of impounded documents and arithmetical accuracy in impounded documents. However, none of such discrepancy / issue raised by the assessee

SIX TWENTY REALTY PVT. LTD.,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 786/RJT/2024[2019-20]Status: DisposedITAT Rajkot11 Mar 2026AY 2019-20
Section 133ASection 143(3)Section 147Section 148Section 250

price with\ncustomer inclusive of all other add-on services provided by him) in various impounded\ndocuments/data as well as averments made by sales employee in his statement,\nestimation of unaccounted receipts at Rs.30.22 crores as well as total receipts at Rs.\n118.31 crores from entire project, i.e., 509 flats is strongly objected.\n\n15. It is also submitted that

DCIT, CENTRAL CIRCLE-1, RAJKOT, RAJKOT vs. SIX TWENTY REALTY PRIVATE LIMITED, RAJKOT

ITA 765/RJT/2024[2019-20]Status: DisposedITAT Rajkot11 Mar 2026AY 2019-20
Section 133ASection 143(3)Section 147Section 148Section 250

price with\ncustomer inclusive of all other add-on services provided by him) in various impounded\ndocuments/data as well as averments made by sales employee in his statement,\nestimation of unaccounted receipts at Rs.30.22 crores as well as total receipts at Rs.\n118.31 crores from entire project, i.e., 509 flats is strongly objected.\n\n15. It is also submitted that

SIX TWENTY REALTY PVT LTD,RAJOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 787/RJT/2024[2020-21]Status: DisposedITAT Rajkot11 Mar 2026AY 2020-21
Section 133ASection 143(3)Section 147Section 148Section 250

price with\ncustomer inclusive of all other add-on services provided by him) in various impounded\ndocuments/data as well as averments made by sales employee in his statement,\nestimation of unaccounted receipts at Rs.30.22 crores as well as total receipts at Rs.\n118.31 crores from entire project, i.e., 509 flats is strongly objected.\n\n15. It is also submitted that

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, RAJKOT vs. SHRI PANKAJ CHIMANLAL LODHIYA, RAJKOT

In the result, assessee's ground No

ITA 102/RJT/2019[2014-15]Status: DisposedITAT Rajkot28 Mar 2025AY 2014-15

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

Section 143(3)

price which is mentioned in the pricelist itself could be the subject matter of cross-examination. Therefore, it was not for the Adjudicating Authority to presuppose as to what could be the subject matter of the cross-examination and make the remarks as mentioned above. We may also point out that on an earlier occasion when the matter came before

THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, RAJKOT vs. SHRI PANKAJ CHIMANLAL LODHIYA, RAJKOT

In the result, assessee's ground No

ITA 46/RJT/2019[2010-11]Status: DisposedITAT Rajkot28 Mar 2025AY 2010-11

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

Section 143(3)

price which is mentioned in the pricelist itself could be the subject matter of cross-examination. Therefore, it was not for the Adjudicating Authority to presuppose as to what could be the subject matter of the cross-examination and make the remarks as mentioned above. We may also point out that on an earlier occasion when the matter came before

THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, RAJKOT vs. SHRI PANKAJ CHIMANLAL LODHIYA, RAJKOT

In the result, assessee's ground No

ITA 49/RJT/2019[2013-14]Status: DisposedITAT Rajkot28 Mar 2025AY 2013-14

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

Section 143(3)

price which is mentioned in the pricelist itself could be the subject matter of cross-examination. Therefore, it was not for the Adjudicating Authority to presuppose as to what could be the subject matter of the cross-examination and make the remarks as mentioned above. We may also point out that on an earlier occasion when the matter came before