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43 results for “transfer pricing”+ Section 153Aclear

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Key Topics

Section 172(4)26Addition to Income24Section 14723Section 143(3)22Section 14816Section 69A10Section 144C9Reopening of Assessment9Section 250

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)

153A will also be contrary to the scheme of the Act as evident from the Notes on Clauses to the Finance Bill 2009 which clearly indicated that the provisions of Section 144C were intended for the foreign companies in respect of matters relating to international taxation and transfer pricing

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

Showing 1–20 of 43 · Page 1 of 3

8
Penalty8
Section 142(1)7
Disallowance6
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)

153A will also be contrary to the scheme of the Act as evident from the Notes on Clauses to the Finance Bill 2009 which clearly indicated that the provisions of Section 144C were intended for the foreign companies in respect of matters relating to international taxation and transfer pricing

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)

153A will also be contrary to the scheme of the Act as evident from the Notes on Clauses to the Finance Bill 2009 which clearly indicated that the provisions of Section 144C were intended for the foreign companies in respect of matters relating to international taxation and transfer pricing

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)

153A will also be contrary to the scheme of the Act as evident from the Notes on Clauses to the Finance Bill 2009 which clearly indicated that the provisions of Section 144C were intended for the foreign companies in respect of matters relating to international taxation and transfer pricing

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)

153A will also be contrary to the scheme of the Act as evident from the Notes on Clauses to the Finance Bill 2009 which clearly indicated that the provisions of Section 144C were intended for the foreign companies in respect of matters relating to international taxation and transfer pricing

SHRI BHARATKUMAR IASHWARBHAI BHATIYA,RAJKOT vs. THE ACIT, CENTRAL CIRL-1,, RAJKOT

In the result, appeals filed by the Revenue, in ITA No

ITA 44/RJT/2023[2006-07]Status: DisposedITAT Rajkot19 Jun 2025AY 2006-07

Bench: Dr. Arjun Lal Saini & Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 134 & 135/Rjt/2023 (िनधा"रणवष" / Assessment Years: (2007-08 & 2008-09) Income Tax Officer, Ward- Shri Kherajmal Lekhrajbjai 5Th 1(2)(1), Aaykar Bhavan, Thavrani, 4- Parsana Nagar, Shri Vs. Floor, Room No. 517, Race Vaheguru Grupa, Near Refugee Course Ring Road, Rajkot-360 Colony, Rajkot-360 001 001 "थायी लेखा सं./जी आइ आर सं./Pan/Gir No.: Adrpt 5807 E (Appellant) (Respondent)

153A of the Act were initiated by issuing notice on 17.01.2013 and 30.07.2013 which were duly served upon the assessee. The assessee was required to file return of income within 30 days of the receipt of the notice. In response to notice, the assessee filed return of income showing total income of Rs.88,340/- on 27.02.2014. A notice

JAMNADAS PURSHOTAM PATEL,RAJKOT vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTER-1, RAJKOT

ITA 60/RJT/2025[2017-18]Status: DisposedITAT Rajkot22 Dec 2025AY 2017-18
Section 250

153A/\n153C/143(3)/ 144 of the Act.\n2. Since, the issues involved in all the appeals are common and identical;\ntherefore, these appeals have been heard together and are being disposed of by\nthis consolidated order.\n3. The revenue has filed the following appeals, which pertain to partnership\nfirms:\n(i).\nM/s Shubham Enterprises

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)

section 153A of the Income-tax Act, 1961 which requires the total income to be brought under tax without any restrictions and On the facts and in the circumstances of the case and in law, the Id. CIT(A) has erred in law in and on facts in holding that such assessment or re-assessment u/s.153A of the Income

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)

section 153A of the Income-tax Act, 1961 which requires the total income to be brought under tax without any restrictions and On the facts and in the circumstances of the case and in law, the Id. CIT(A) has erred in law in and on facts in holding that such assessment or re-assessment u/s.153A of the Income

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)

section 153A of the Income-tax Act, 1961 which requires the total income to be brought under tax without any restrictions and On the facts and in the circumstances of the case and in law, the Id. CIT(A) has erred in law in and on facts in holding that such assessment or re-assessment u/s.153A of the Income

THE INCOME TAX OFFICER-WARD-2,, JUNAGADH vs. SHRI DAMJIBHAI LEKHRAJBHAI THAVRANI,, JUNAGADH

ITA 32/RJT/2019[2010-11]Status: DisposedITAT Rajkot19 Jun 2025AY 2010-11
Section 132Section 143(2)Section 153ASection 271(1)(c)

153A of the Act were initiated by\nissuing notice on 17.01.2013 and 30.07.2013 which were duly served upon the\nassessee. The assessee was required to file return of income within 30 days of\nthe receipt of the notice. In response to notice, the assessee filed return of\nincome showing total income of Rs.88,340/- on 27.02.2014. A notice

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

Appeals are dismissed, Assessee's appeals are partly allowed

ITA 47/RJT/2019[2011-12]Status: DisposedITAT Rajkot28 Mar 2025AY 2011-12

section 153A of the\nIncome-tax Act, 1961 which requires the total income to be brought under tax without any\nrestrictions and On the facts and in the circumstances of the case and in law, the Id. CIT(A)\nhas erred in law and on facts in holding that such assessment or re-assessment u/s.153A of\nthe Income

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

ITA 48/RJT/2019[2012-13]Status: DisposedITAT Rajkot28 Mar 2025AY 2012-13

section 153A of the\nIncome-tax Act, 1961 which requires the total income to be brought under tax without any\nrestrictions and On the facts and in the circumstances of the case and in law, the Id. CIT(A)\nhas erred in law and on facts in holding that such assessment or re-assessment u/s.153A of\nthe Income

SHRI BHARATKUMAR IASHWARBHAI BHATIYA,RAJKOT vs. THE ITO, WARD-1 (1) (2),, RAJKOT

ITA 46/RJT/2023[2013-14]Status: DisposedITAT Rajkot19 Jun 2025AY 2013-14

153A of the Act were initiated by\nissuing notice on 17.01.2013 and 30.07.2013 which were duly served upon the\nassessee. The assessee was required to file return of income within 30 days of\nthe receipt of the notice. In response to notice, the assessee filed return of\nincome showing total income of Rs.88,340/- on 27.02.2014. A notice

SHRI DAMJIBHAI LEKHRAJBHAI THAVRANI,,JUNAGADH vs. THE INCOME TAX OFFICER-WARD 1(2)(4),, RAJKOT

ITA 16/RJT/2019[2010-11]Status: DisposedITAT Rajkot19 Jun 2025AY 2010-11

153A of the Act were initiated by issuing notice on 17.01.2013 and 30.07.2013 which were duly served upon the assessee. The assessee was required to file return of income within 30 days of the receipt of the notice. In response to notice, the assessee filed return of income showing total income of Rs.88,340/- on 27.02.2014. A notice

SHRI BHARATKUMAR ISHWARBHAI BHATIYA,RAJKOT-GUJARAT vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,, RAJKOT-GUJARAT

ITA 171/RJT/2015[2006-07]Status: DisposedITAT Rajkot19 Jun 2025AY 2006-07

153A of the Act were initiated by\nissuing notice on 17.01.2013 and 30.07.2013 which were duly served upon the\nassessee. The assessee was required to file return of income within 30 days of\nthe receipt of the notice. In response to notice, the assessee filed return of\nincome showing total income of Rs.88,340/- on 27.02.2014. A notice

THE INCOME TAX OFFICER-WARD-2,, JUNAGADH vs. SHRI DAMJIBHAI LEKHRAJBHAI THAVRANI,, JUNAGADH

ITA 33/RJT/2019[2011-12]Status: DisposedITAT Rajkot19 Jun 2025AY 2011-12

153A of the Act were initiated by\nissuing notice on 17.01.2013 and 30.07.2013 which were duly served upon the\nassessee. The assessee was required to file return of income within 30 days of\nthe receipt of the notice. In response to notice, the assessee filed return of\nincome showing total income of Rs.88,340/- on 27.02.2014. A notice

THE DY. COMMR. OF INCOME TAX, CEN. CIR.-1,, RAJKOT vs. BHARATKUMAR ISHWARBHAI BHATIYA,, RAJKOT

ITA 49/RJT/2018[2013-14]Status: DisposedITAT Rajkot19 Jun 2025AY 2013-14

153A of the Act were initiated by\nissuing notice on 17.01.2013 and 30.07.2013 which were duly served upon the\nassessee. The assessee was required to file return of income within 30 days of\nthe receipt of the notice. In response to notice, the assessee filed return of\nincome showing total income of Rs.88,340/- on 27.02.2014. A notice

SHRI BHARATKUMAR IASHWARBHAI BHATIYA,RAJKOT vs. THE ITO, WARD-1 (1) (2),, RAJKOT

ITA 45/RJT/2023[2012-13]Status: DisposedITAT Rajkot19 Jun 2025AY 2012-13
Section 132Section 143(2)Section 153ASection 271(1)(c)

153A of the Act were initiated by\nissuing notice on 17.01.2013 and 30.07.2013 which were duly served upon the\nassessee. The assessee was required to file return of income within 30 days of\nthe receipt of the notice. In response to notice, the assessee filed return of\nincome showing total income of Rs.88,340/- on 27.02.2014. A notice

KIRAN HARUBHAI DANGAR,JUNAGADH vs. ASSESSING OFFICER, RAJKOT

ITA 368/RJT/2023[2012-13]Status: DisposedITAT Rajkot10 Apr 2026AY 2012-13

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

For Appellant: Shri D. M. Rindani, ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr. DR
Section 132Section 142(1)Section 143(2)Section 143(3)Section 148Section 153BSection 153CSection 250Section 69

153A and section 153B of the Act. (ii). The order of assessment passed u/s 143(3) r.w.s. 147 of the Act and the order u/s 250 of the Act are bad in law as they are passed without Document Identification Number (DIN) mentioning therein and hence they are to be treated as invalid in view of CBDT Circular No. 19/2019