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2 results for “transfer pricing”+ Section 64clear

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Key Topics

Transfer Pricing2

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 adjustment in respect of such transaction Chapter X does not arise and therefore, question (3) is answered in the negative and in favour of the Assessee and against the Revenue." vi. Bausch & Lomb Eyecare India Pvt Ltd [ITA 63/2014] The relevant extract for the same is as follows: "There is merit in the contention of the Assessee that

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

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

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

64,429/- being Rs.20,53,221/- had made without considering the fact that the asessee itself has disallowed Rs.,2,27,69,056/-. In the ground, the assessee has prayed for reduction of the disallowance of 5% on the balance amount after reducing the disallowance made by the assessee. It was the submission that consequently, itis a total disallowance