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2 results for “transfer pricing”+ Section 73(4)clear

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Key Topics

Section 2634

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

Pricing Officer was of the view that the license granted by Cummins to the assessee included any R&D development done by Tata Cummins Vs DCIT the assessee on the engine technology and the patents which was owned by Cummins and therefore, the R&D developments that has been done by the assessee was owned by Cummins Incorporated

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

4 Ashok Kr. Pandey Vs PCIT "That Ld. PCIT Dhanbad initiated proceedings u/s 263 on the ground that Ld. AO has completed the assessment without making enquiries and verifications in respect of below mentioned items:- (a) Major expenses claimed: (i) Labour payment of ₹ 46,02,250/- (ii) Purchase of bricks of ₹ 9,30,150/- (iii) Stone chips