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3 results for “transfer pricing”+ Section 10(15)clear

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Key Topics

Transfer Pricing3Disallowance2Addition to Income2

TATA CUMMINS PRIVATE LIMITED,PUNE vs. THE DCIT CIRCLE-1-JAMSHEDPUR AND THE ASSESSMENT UNIT, INCOME-TAX DEPARTMENT, NFAC, DELHI, JAMSHEDPUR

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 430/RAN/2024[2021-22]Status: DisposedITAT Ranchi12 Jun 2025AY 2021-22

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaytata Cummins Private Limited, D.C.I.T., Cummins India Office, Tower-A, 7Th Circle-1, Vs. Floor, Survey No. 21, Balewadi, Pune, Jamshedpur. Maharashtra. Pan No. Aaact 6353 L Appellant/ Assessee Respondent/ Revenue

10,90,71,239/- Lakhs. The said R&D expenses incurred by the Assessee are in the nature of testing expenses, salaries and wages of the personnel involved, travel etc. The details of R&D expenditure debited to P&L are tabulated below: Nature of Expense Amount (In Lakhas) Salareis & Wages 220 Material, Spares and 73 Consumables Testing Expenses

TIMKEN INDIA LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, JAMSHEDPUR, JAMSHEDPUR

In the result, appeal of the assessee stands partly allowed

ITA 92/RAN/2022[2017-18]Status: DisposedITAT Ranchi12 Jun 2025AY 2017-18

BEFORES/SHRI GEORGE MATHAN, JUDICIAL MEMBER AND RATNESH NANDAN SAHAY (Accountant Member)

Bench:
For Appellant: S/Shri K.M.Gupta/Krishan Shaw, ARsFor Respondent: Smt. Rinku Singh, CIT DR
Section 115JSection 14ASection 234D

transfer pricing is in regard to whetherthe resale price method is to be applied or TNMM method is to be applied. The resale method admittedly has been applies where the assessee purchase of particular product when sale it. The profit margin should be comparable. Now what the assessee purchases is bearing. These bearings are purchased at the instance

M/S USHA MARTIN LTD,KOLKATA vs. ACIT CIR-3, RANCHI

In the result, appeal of the assessee stands partly allowed for statistical purposes

ITA 68/RAN/2017[2007-08]Status: DisposedITAT Ranchi12 Jun 2025AY 2007-08

Bench: BEFORES/SHRI GEORGE MATHAN, JUDICIAL MEMBER AND RATNESH NANDAN SAHAY (Accountant Member)

For Appellant: S/Shri Aditya Hans/Vishal Jain and Ashis JainFor Respondent: Smt. Rinku Singh, CIT DR
Section 234Section 244A

section 234 B and 234D, theseare consequential in nature. Consequently, additional grounds raised by the assessee stand disposed as per the above direction. 9. Now coming to the main appeal filed the assessee, Ground No.1 is general in nature and consequently not adjudicated. 10. In Ground No.2, the same has three limbs. In Ground No.2.2, most specifically Ground No.2.2.2