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2 results for “transfer pricing”+ Section 35(1)(i)clear

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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

Section 35(1)(i). It was a submission that the said R&D led to modifications so as to meet the local emission requirements and as per the agreement the said modifications also belonged to the AE being Cummins Incorporated. 14 Tata Cummins Vs DCIT 4. We have considered the rival submissions. A specific query was raised

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, Advocate
For Respondent: Shri Khubchand T. Pandya, Sr. DR
Section 250

1) dated 03.04.2024 passed u/s. 250 of the Income Tax\nAct, 1961 (hereinafter referred to as “the Act”) for AY 2017-18.\n2.\nShri Khubchand T. Pandya, Sr. DR appeared on behalf of the revenue\nand Shri Anil Kumar Jha, Advocate appeared on behalf of the assessee.\n3. It was submitted by the Ld. AR that the assessee