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3 results for “transfer pricing”+ Section 9(1)(v)clear

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Key Topics

Section 2634Transfer Pricing2Addition 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

1) 5CC 467 wherein it was held that the charge of excise duty is 6 Tata Cummins Vs DCIT on manufacture while the measure of the tax is the selling price of the manufactured goods. In this case also the charge is on income as understood in the Act, and where income arises from an International Transaction, then the measure

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 2025AY 2017-18

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

Bench:
For Appellant: S/Shri K.M.Gupta/Krishan Shaw, ARsFor Respondent: Smt. Rinku Singh, CIT DR
Section 115JSection 14ASection 234D

transfer pricing addition. Ground No.5.1 and 5.2 related to the disallowance u/s.14A r.w. Rule 8D of the Act, both under the normal provisions of the Act as well as in respect of book profit computed under section 115JB of the Act. In regard to Ground No.6, it was the submission that this issue related to the incorrect payment of refund

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

9,30,150/- (iii) Stone chips of ₹ 3,20,900/- (iv) Sand of ₹ 2,94,500/- (v) Steel of ₹ 11,78,852/- (vi) Plumbing material of ₹ 1,61,090/- (vii) Marble & Tiles of ₹ 17,73,356/- (b) Payment made to land owner of ₹ 31,06,375/- (c) Source & Advance of ₹ 10,42,27,450/- received in lieu of allotment