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5 results for “transfer pricing”+ Section 12clear

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Key Topics

Section 2634Transfer Pricing3Addition to Income3Disallowance2

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 2025
AY 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

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

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