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14 results for “transfer pricing”+ Section 12clear

Sorted by relevance

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Key Topics

Section 143(3)13Addition to Income11Section 69B7Section 406Section 2635Section 50C5Section 1474Section 1483Section 56(2)(vii)3

M/S ADITYA BIRLA CHEMICALS INDIA LTD.,PALAMAU vs. ACIT, RANCHI

In the result, Assessee`s appeals are allowed and Revenue`s appeals are dismissed and cross objections filed by the assessee are allowed to the extent indicated above

ITA 126/RAN/2015[2009-10]Status: DisposedITAT Ranchi08 Jul 2020AY 2009-10

Bench: Shri S.S.Godara, Jm & Dr. A. L. Saini, Am I.T.A Nos. 125 To 127/Ran/2015 Assessment Years: 2008-09 To 2010-11 M/S. Aditya Birla Chemicals India Vs. Acit, Circle – 1, Ltd. (Formerly Known As Bihar Ranchi Caustic & Chemicals Ltd.) Rehla, Palamau – 822124. Pan/Gir No. : Aaacb 7747 A (Appellant) .. (Respondent)

Section 143(3)Section 40

12. On appeal, the CIT(A) has given part relief to the assessee. Hence, both the sides are in appeal before us. 13. Ld counsel for the assessee submitted that the CIT(A) has allowed the claim of the assessee partly by calculating the market price of electricity after reducing the duty paid therein. Ld counsel submitted that

ACIT, RANCHI vs. M/S M/S ADITYA BIRLA CHEMICALS INDIA LTD., PALAMAU

In the result, Assessee`s appeals are allowed and Revenue`s appeals are dismissed and cross objections filed by the assessee are allowed to the extent indicated above

Capital Gains3
Transfer Pricing3
Disallowance2
ITA 136/RAN/2015[2009-10]Status: DisposedITAT Ranchi08 Jul 2020AY 2009-10

Bench: Shri S.S.Godara, Jm & Dr. A. L. Saini, Am I.T.A Nos. 125 To 127/Ran/2015 Assessment Years: 2008-09 To 2010-11 M/S. Aditya Birla Chemicals India Vs. Acit, Circle – 1, Ltd. (Formerly Known As Bihar Ranchi Caustic & Chemicals Ltd.) Rehla, Palamau – 822124. Pan/Gir No. : Aaacb 7747 A (Appellant) .. (Respondent)

Section 143(3)Section 40

12. On appeal, the CIT(A) has given part relief to the assessee. Hence, both the sides are in appeal before us. 13. Ld counsel for the assessee submitted that the CIT(A) has allowed the claim of the assessee partly by calculating the market price of electricity after reducing the duty paid therein. Ld counsel submitted that

M/S ADITYA BIRLA CHEMICALS INDIA LTD.,PALAMAU vs. ACIT, RANCHI

In the result, Assessee`s appeals are allowed and Revenue`s appeals are dismissed and cross objections filed by the assessee are allowed to the extent indicated above

ITA 125/RAN/2015[2008-09]Status: DisposedITAT Ranchi08 Jul 2020AY 2008-09

Bench: Shri S.S.Godara, Jm & Dr. A. L. Saini, Am I.T.A Nos. 125 To 127/Ran/2015 Assessment Years: 2008-09 To 2010-11 M/S. Aditya Birla Chemicals India Vs. Acit, Circle – 1, Ltd. (Formerly Known As Bihar Ranchi Caustic & Chemicals Ltd.) Rehla, Palamau – 822124. Pan/Gir No. : Aaacb 7747 A (Appellant) .. (Respondent)

Section 143(3)Section 40

12. On appeal, the CIT(A) has given part relief to the assessee. Hence, both the sides are in appeal before us. 13. Ld counsel for the assessee submitted that the CIT(A) has allowed the claim of the assessee partly by calculating the market price of electricity after reducing the duty paid therein. Ld counsel submitted that

ACIT, RANCHI vs. M/S ADITYA BIRLA CHEMICALS INDIA LTD., PALAMAU

In the result, Assessee`s appeals are allowed and Revenue`s appeals are dismissed and cross objections filed by the assessee are allowed to the extent indicated above

ITA 137/RAN/2015[2010-11]Status: DisposedITAT Ranchi08 Jul 2020AY 2010-11

Bench: Shri S.S.Godara, Jm & Dr. A. L. Saini, Am I.T.A Nos. 125 To 127/Ran/2015 Assessment Years: 2008-09 To 2010-11 M/S. Aditya Birla Chemicals India Vs. Acit, Circle – 1, Ltd. (Formerly Known As Bihar Ranchi Caustic & Chemicals Ltd.) Rehla, Palamau – 822124. Pan/Gir No. : Aaacb 7747 A (Appellant) .. (Respondent)

Section 143(3)Section 40

12. On appeal, the CIT(A) has given part relief to the assessee. Hence, both the sides are in appeal before us. 13. Ld counsel for the assessee submitted that the CIT(A) has allowed the claim of the assessee partly by calculating the market price of electricity after reducing the duty paid therein. Ld counsel submitted that

M/S ADITYA BIRLA CHEMICALS INDIA LTD.,PALAMAU vs. ACIT, RANCHI

In the result, Assessee`s appeals are allowed and Revenue`s appeals are dismissed and cross objections filed by the assessee are allowed to the extent indicated above

ITA 127/RAN/2015[2010-11]Status: DisposedITAT Ranchi08 Jul 2020AY 2010-11

Bench: Shri S.S.Godara, Jm & Dr. A. L. Saini, Am I.T.A Nos. 125 To 127/Ran/2015 Assessment Years: 2008-09 To 2010-11 M/S. Aditya Birla Chemicals India Vs. Acit, Circle – 1, Ltd. (Formerly Known As Bihar Ranchi Caustic & Chemicals Ltd.) Rehla, Palamau – 822124. Pan/Gir No. : Aaacb 7747 A (Appellant) .. (Respondent)

Section 143(3)Section 40

12. On appeal, the CIT(A) has given part relief to the assessee. Hence, both the sides are in appeal before us. 13. Ld counsel for the assessee submitted that the CIT(A) has allowed the claim of the assessee partly by calculating the market price of electricity after reducing the duty paid therein. Ld counsel submitted that

ACIT, RANCHI vs. M/S M/S ADITYA BIRLA CHEMICALS INDIA LTD., PALAMAU

In the result, Assessee`s appeals are allowed and Revenue`s appeals are dismissed and cross objections filed by the assessee are allowed to the extent indicated above

ITA 131/RAN/2015[2008-09]Status: DisposedITAT Ranchi08 Jul 2020AY 2008-09

Bench: Shri S.S.Godara, Jm & Dr. A. L. Saini, Am I.T.A Nos. 125 To 127/Ran/2015 Assessment Years: 2008-09 To 2010-11 M/S. Aditya Birla Chemicals India Vs. Acit, Circle – 1, Ltd. (Formerly Known As Bihar Ranchi Caustic & Chemicals Ltd.) Rehla, Palamau – 822124. Pan/Gir No. : Aaacb 7747 A (Appellant) .. (Respondent)

Section 143(3)Section 40

12. On appeal, the CIT(A) has given part relief to the assessee. Hence, both the sides are in appeal before us. 13. Ld counsel for the assessee submitted that the CIT(A) has allowed the claim of the assessee partly by calculating the market price of electricity after reducing the duty paid therein. Ld counsel submitted that

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

Transfer Pricing Guidelines, para 7.13 emphasises that there should not be any automatic inference about an AE receiving an entity group service only because it gets on incidental benefit for being part of a larger concern and not to any specific activity performed" 10.14 In addition, the Assessee further submits that the commercial expediency/ business rationale of a particular expenditure

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

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

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

section 115-O of the Act and not at the rate of tax applicable to the non-resident shareholder(s) as specified in the relevant DTAA with reference to such dividend income. Nevertheless, we are conscious of the sovereign's prerogative to extend the treaty protection to domestic companies paying dividend distribution tax through the mechanism of DTAAs. Thus, wherever

SUNITA ADUKIA,RANCHI vs. DCIT CIR-2, RANCHI

In the result, appeal is partly allowed

ITA 15/RAN/2018[13-14]Status: DisposedITAT Ranchi30 Oct 2019

Bench: S/Shri Chandra Mohan Gargassessment Year: 2013-14

For Appellant: Shri Rajiv Ranjan Mittal, CAFor Respondent: Shri P.K.Mondal, Addl. CIT(DR)
Section 132Section 143(3)Section 153Section 153ASection 54

price. (iv) For that the order passed u/s 143(3) of the Income Tax Act, 1961, treating the Long Term Capital Gains as Short Term Capital Gain is bad in law as well as in facts and against the Principles of natural justice and therefore liable to be set aside. P a g e 2 | 17 ITA No.14 & 15/Ran/2018 Assessment

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

transfer pricing, it was submitted that the assessee is in the business of manufacture of steel wire, steel ropes, wire rods, billets, wires, and other steel products etc. It was the submission that the products manufactured by the assessee was in the realm of steel. The assessee had provided its TNMM calculation and had given multiple

ASHOK KUMAR PANDEY,DHANBAD vs. PR. CIT, DHANBAD

In the result, this appeal of assessee is allowed

ITA 11/RAN/2022[2017-18]Status: DisposedITAT Ranchi24 Mar 2025AY 2017-18

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

Section 143(1)Section 143(2)Section 143(3)Section 263

12,37,58,750.43 for 2 Ashok Kr. Pandey Vs PCIT the financial year under consideration and when asked to explain the reasons for high closing stocks, the learned Authorised Representative (ld. AR) of the assessee submitted on 16/02/2019 that during relevant financial year, some projects were completed and most of the projects were shown under 'work in progress' since

DCIT CIRCLE-1, RANCHI vs. SHRI ANUP CHAWLA, RANCHI

In the result, the appeal of the revenue is dismissed

ITA 8/RAN/2017[2012-13]Status: DisposedITAT Ranchi22 Feb 2019AY 2012-13

Bench: Shri S. S. Godara, J.M. & Dr.A.L.Saini, A.M.)

For Appellant: None appearedFor Respondent: Shri Chandan Das, JCIT/ld.DR
Section 143(3)Section 48Section 50CSection 56(2)(vii)Section 69B

price of the property at Rs. 45,00,000/- and stamp duty of Rs. 9,70,500/- and registration and other charges at Rs. 7,39,500/-. The value taken by the ld. Assessing Officer was the value charged by the Government for Stamp Duty purposes. The appellant submitted before AO that the provisions of section

SUDHIR KUMAR JHA,BOKARO STEEL CITY vs. ACIT OR DCIT, CIRCLE-3, BOKARO

In the result, the appeal of the assessee is dismissed

ITA 131/RAN/2024[2017-2018]Status: DisposedITAT Ranchi24 Apr 2025AY 2017-2018
For Appellant: Shri Anil Kumar Jha, AdvocateFor Respondent: Shri Khubchand T. Pandya, Sr. DR
Section 250

price. He has also sold paddy in 2012 to\ngovernment agencies and has received payment through cheque. A perusal\nof the details of the land sold as has been provided by Shri Sunil Kumar\nJha along with a certificate shows that the land was sold between\n08.12.2010 and 19.12.2016. The certificate issued by Shri Sunil Kumar\nJha says that

OM PRAAKSH SINGH,RANCHI vs. DCIT, CIRCLE-1, RANCHI

In the result, appeal filed by the assessee is allowed

ITA 361/RAN/2018[2009-10]Status: DisposedITAT Ranchi10 Sept 2020AY 2009-10

Bench: Shri S.S, Godara, Jm & Dr. A.L. Saini, Am Om Prakash Singh Vs. Dcit, Circle-1, Ranchi Sankalp, East Jail Road, Ranchi- 834001. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Agkps0300D (अपीलाथ" /Appellant) .. (""थ" / Respondent)

For Appellant: Shri Manjit Verma, A/RFor Respondent: Shri A. K. Mohanti, JCIT, Sr. DR
Section 142(1)Section 143(3)Section 147Section 148Section 234CSection 263Section 37(1)

section 148 of the Act was issued to assessee on 31.12.2016. In the assessee`s case the relevant assessment year is 2009-10, therefore the assessee`s case was reopened after the expiry of 4 Years from the end of the relevant assessment year. The settled position of law is that if an assessment for any year has been completed