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4 results for “transfer pricing”+ Section 14clear

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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

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

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

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

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

14. Payments were received in cash till Sept. 16 and registry was done on\n19.12.2016.\nMy\nmain\nsource\nof income is agricultural income, excluding\nagricultural income, does not exceed the basic exemption limit for filing income\nand total\nnet\nincome\n4.\ntax\nreturn. Copy of PAN enclosed as Annexure-2. Land ownership certicale for some larids\nin village Bardaha from