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36 results for “transfer pricing”+ Section 153A(1)clear

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Key Topics

Section 172(4)26Section 143(3)21Addition to Income19Section 14717Section 14814Section 144C9Section 2508Section 69A8Reopening of Assessment

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 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)

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any foreign company.' 8. If the above provisions of reference to the DRP are to be applied in the context of orders passed under section 172(4), in terms of the provisions of Section 144(1), it is incumbent upon the Assessing Officer to first forward

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

Showing 1–20 of 36 · Page 1 of 2

8
Section 142(1)6
Penalty6
Disallowance5

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)

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any foreign company.' 8. If the above provisions of reference to the DRP are to be applied in the context of orders passed under section 172(4), in terms of the provisions of Section 144(1), it is incumbent upon the Assessing Officer to first forward

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)

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any foreign company.' 8. If the above provisions of reference to the DRP are to be applied in the context of orders passed under section 172(4), in terms of the provisions of Section 144(1), it is ITA Nos. 756 of 2014, 276 of 2015 & 91/Rjt/2016

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)

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any foreign company.' 8. If the above provisions of reference to the DRP are to be applied in the context of orders passed under section 172(4), in terms of the provisions of Section 144(1), it is ITA Nos. 756 of 2014, 276 of 2015 & 91/Rjt/2016

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)

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any foreign company.' 8. If the above provisions of reference to the DRP are to be applied in the context of orders passed under section 172(4), in terms of the provisions of Section 144(1), it is ITA Nos. 756 of 2014, 276 of 2015 & 91/Rjt/2016

THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHIDHAM-KUTCH vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM-KUTCH

In the result, cross objections filed by the assessee are allowed for statistical purposes

ITA 366/RJT/2017[2013-14]Status: DisposedITAT Rajkot17 Mar 2025AY 2013-14

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

For Appellant: Shri K. C. Thacker, Ld. A.RFor Respondent: Shri Sanjay Punglia,Ld.CIT (DR)
Section 36(1)(iii)

153A(1) (b)/143(3) of the Income Tax Act, 1961,( hereinafter referred to as “the Act”). 2. Since, these five appeals filed by the Revenue and four cross objections of assessee, pertain to the same assessee and identical and common issues are involved, therefore, these appeals of revenue and cross objections of assessee, have been clubbed and heard together

THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHINAGAR vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM

In the result, cross objections filed by the assessee are allowed for statistical purposes

ITA 233/RJT/2016[2009-10]Status: DisposedITAT Rajkot17 Mar 2025AY 2009-10

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

For Appellant: Shri K. C. Thacker, Ld. A.RFor Respondent: Shri Sanjay Punglia,Ld.CIT (DR)
Section 36(1)(iii)

153A(1) (b)/143(3) of the Income Tax Act, 1961,( hereinafter referred to as “the Act”). 2. Since, these five appeals filed by the Revenue and four cross objections of assessee, pertain to the same assessee and identical and common issues are involved, therefore, these appeals of revenue and cross objections of assessee, have been clubbed and heard together

THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHINAGAR vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM

In the result, cross objections filed by the assessee are allowed for statistical purposes

ITA 235/RJT/2016[2011-12]Status: DisposedITAT Rajkot17 Mar 2025AY 2011-12

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

For Appellant: Shri K. C. Thacker, Ld. A.RFor Respondent: Shri Sanjay Punglia,Ld.CIT (DR)
Section 36(1)(iii)

153A(1) (b)/143(3) of the Income Tax Act, 1961,( hereinafter referred to as “the Act”). 2. Since, these five appeals filed by the Revenue and four cross objections of assessee, pertain to the same assessee and identical and common issues are involved, therefore, these appeals of revenue and cross objections of assessee, have been clubbed and heard together

THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHINAGAR vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM

In the result, cross objections filed by the assessee are allowed for statistical purposes

ITA 234/RJT/2016[2010-11]Status: DisposedITAT Rajkot17 Mar 2025AY 2010-11

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

For Appellant: Shri K. C. Thacker, Ld. A.RFor Respondent: Shri Sanjay Punglia,Ld.CIT (DR)
Section 36(1)(iii)

153A(1) (b)/143(3) of the Income Tax Act, 1961,( hereinafter referred to as “the Act”). 2. Since, these five appeals filed by the Revenue and four cross objections of assessee, pertain to the same assessee and identical and common issues are involved, therefore, these appeals of revenue and cross objections of assessee, have been clubbed and heard together

THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHINAGAR vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM

In the result, cross objections filed by the assessee are allowed for statistical purposes

ITA 236/RJT/2016[2012-13]Status: DisposedITAT Rajkot17 Mar 2025AY 2012-13

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

For Appellant: Shri K. C. Thacker, Ld. A.RFor Respondent: Shri Sanjay Punglia,Ld.CIT (DR)
Section 36(1)(iii)

153A(1) (b)/143(3) of the Income Tax Act, 1961,( hereinafter referred to as “the Act”). 2. Since, these five appeals filed by the Revenue and four cross objections of assessee, pertain to the same assessee and identical and common issues are involved, therefore, these appeals of revenue and cross objections of assessee, have been clubbed and heard together

KANDLA EXPORT CORPORATION,,GANDHIDHAM vs. THE DY. COMMR. OF INCOME TAX, CEN. CIR.-2(3),, AHMEDABAD

In the result, the summaries and concise ground No

ITA 155/RJT/2016[2012-13]Status: DisposedITAT Rajkot28 Feb 2025AY 2012-13

Bench: Dr. Arjun Lal Saini, Am.& Dinesh Mohan Sinha, Jm आयकरअपीलसं./It(Ss)A No.135/Ahd/2016 ("नधा"रणवष" / Assessment Year: (2011-12) (Hybrid Hearing) The Deputy Commissioner Of Vs. Kandla Exports Corporation Income – Tax, Central Circle – 2(3), Plot No. 18, Maitri Bhavan, 3Rd Floor, A – 305, Aayakar Bhavan, Sector – 8, Gandhidham, Ahmedabad – 370201 Kutch- 370201 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacfk1906F (Assessee) (Respondent) आयकरअपीलसं./It(Ss)A No.136/Ahd/2016 ("नधा"रणवष" / Assessment Year: (2012-13) (Hybrid Hearing) The Deputy Commissioner Of Kandla Exports Corporation Vs Income – Tax, Central Circle – Plot No. 18, Maitri Bhavan, . 2(3), 3Rd Floor, A – 305, Aayakar Sector – 8, Gandhidham, Bhavan, Ahmedabad - 370201 Kutch- 370201 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacfk1906F (Assessee) (Respondent)

153A(1)(b)/ 143(3) of the Income Tax Act 1961 ( hereinafter referred to as the ‘Act’). 2. Since, the issues involved in all the appeals of Revenue and Assessee, and cross objections of the assessee, are common and identical; therefore, these appeals and cross objections, have been heard together and are being disposed of by this consolidated order

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

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 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 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

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

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

price with customer inclusive of all other add-on services provided by him) in various impounded documents/data as well as averments made by sales employee in his statement, estimation of unaccounted receipts at Rs. 30.22 crores as well as total receipts at Rs. 118.31 crores from entire project, i.e., 509 flats is strongly objected. 15. It is also submitted that

THE ITO WARD-1 (2) (1),, RAJKOT vs. SHRI KHRAJMAL LEKHRAJBHAI THAVRANI, RAJKOT

ITA 134/RJT/2023[2007-08]Status: DisposedITAT Rajkot19 Jun 2025AY 2007-08

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

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 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 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