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37 results for “transfer pricing”+ Exemptionclear

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Key Topics

Section 143(3)38Section 26331Addition to Income30Section 14817Section 10(37)17Disallowance13Section 143(2)12Section 254(1)12Section 37(1)11

INCOME TAX OFFICER WARD - 1(1)(1), SURAT vs. V R SURAT PVT. LTD. FORMERLY KNOWN AS M/S DHANLAXMI INFRASTRUCTURE PVT. LTD., SURAT

In the result, cross objection filed by the assessee (in CO

ITA 329/SRT/2022[2015-16]Status: DisposedITAT Surat27 Jul 2023AY 2015-16

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.329/Srt/2022 Assessment Year: (2015-16) (Physical Hearing) Income Tax Officer, Ward- Vs. V R Surat Pvt. Ltd. 1(1)(1), Surat, Room No.111, 1St (Formerly Known As M/S. Floor, Aayakar Bhawan, Majura Dhanlaxmi Infrastructure Pvt. Gate, Surat-395001 Ltd.,).F. No.29, Virtuous Retail, Surat Dumas, Nr. Dumas Resort, Magdalla, Surat– 395007 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaccd5578R (Assessee) (Respondent) ""या"ेप. सं./Co No.16/Srt/2022 [Arising Out Of Ita No.329/Srt/2022] Assessment Year: (2015-16)

Section 14Section 143(3)

Price of the above a specified International Transactions.” 14. Therefore, we note that for AY.2013-14, the Assessing Officer had accepted the coupon rate of the same FCCDs. Only factual difference was in that year the same debentures were held by another AE located in Cyprus. It is a well settled legal position that factual matters which permeate through more than

HUBERGROUP INDIA PRIVATE LIMITED,VAPI vs. PR. COMMISSIONER OF INCOME TAX, VALSAD

Showing 1–20 of 37 · Page 1 of 2

Section 14710
Capital Gains10
Deduction9

In the result, appeal of the assessee is dismissed

ITA 133/SRT/2022[2018-19]Status: DisposedITAT Surat06 Jun 2023AY 2018-19

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.133/Srt/2022 (Ay 2018-19) (Hearing In Virtual Court) Hubergroup India Pvt. Ltd. Principal Commissioner Of Plot No.808/E, Phase-Ii, Income Tax, Valsad, Room Vs Gidc, Vapi-396195 No.301, 3Rd Floor, Income Tax Pan No. Aaach 7063 F Office, Palak Arcade, Pali Hill, Santi Nagar, Tithal Road, Valsad-396001 ""थ" /Respondent अपीलाथ"/Appellant

Section 143(1)Section 143(3)Section 144BSection 254(1)Section 263Section 80ISection 92C

Transfer Pricing Officer (TPO for short) for determination of Arm’s Length Price (ALP for short) in respect of International Transactions only. The report of TPO was 3 Hubergroup India Pvt. Ltd. received on 31.03.2021 in suggesting certain upward adjustment of Rs.12.58 crores in respect of International Transactions. Accordingly, such upward adjustment was added in the assessment order. However, with

HARIKRISHNA JEWELS,SURAT vs. PR. COMMISSIONER OF INCOME TAX,, SURAT

In the result, appeal of the assessee is allowed for statistical purpose

ITA 354/SRT/2023[2012-13]Status: DisposedITAT Surat15 Apr 2025AY 2012-13

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.354/Srt/2023 Assessment Year: 2012-13 (Physical Court Hearing) Harikrishna Jewels, Principal Commissioner Of 201, Sunstar Building, Opp. बनाम/ Income Tax-1,, Surat, Room New Patidar Bhavan, No.123, Aaykar Bhawan, Near Vs. Mahidharpura, Surat-395 Majura Gate, Opp. New Civil 003 Hospital, Surat -395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aagfh 3864 F (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Assessee By Shri Rasesh Shah, Ca राज" की ओर से /Revenue By Shri Ravi Kant Gupta, Cit-Dr सुनवाई की तारीख/Date Of Hearing 10.02.2025 उद्घोषणा की तारीख/Date Of Pronouncement 15.04.2025

Section 10ASection 143(3)Section 148Section 263

exemption of Rs.5,51,33,350/- claimed u/s 10AA of the Act is required to be disallowed. Accordingly, assessment order passed u/s 143(3) r.w.s. 147 of the Act dated 25.12.2019 was set aside on the pretext that no enquiry was undertaken by the AO in respect of manufacturing activities undertaken by the appellant in the Special Economic Zone

GAUTAM PRAVINCHANDRA SHETH HUF,SURAT vs. PCIT-1, SURAT

In the result, the appeal of the assessee is dismissed

ITA 343/SRT/2025[2018-19]Status: DisposedITAT Surat18 Nov 2025AY 2018-19

Bench: Ms. Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita No.343 & 344/Srt/2025 Assessment Year: (2018-19) Kanchanben Pravinbhai Sheth Vs. Pcit - 1, Surat 3/A, 1 St Floor, Royal Vila Apts., Surat Ghoddod Road, Surat (Jao: Ito, Ward – 1(3)(1), Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Adops2971D (Appellant) (Respondent) Gautam Pravinbhai Sheth (Huf) Vs. Pcit - 1, 3/A, 1 St Floor, Royal Vila Apts., Surat Ghoddod Road, Surat (Jao: Ito, Ward – 1(3)(1), Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aafhg1435A (Appellant) (Respondent) Appellant By Shri Sapnesh Sheth, Advocate Respondent By Ms. Namita Patel, Sr. Dr Date Of Hearing 25/08/2025 Date Of Pronouncement 18/11/2025

Section 10(38)Section 147Section 263

Transfer Pricing Officer, as the case may be, shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner,- (a) the order is passed without making inquiries or verification which should have been made

SMT. KANCHANBEN PRAVINBHAI SHETH,SURAT vs. PCIT-1, SURAT

In the result, the appeal of the assessee is dismissed

ITA 344/SRT/2025[2018-19]Status: DisposedITAT Surat18 Nov 2025AY 2018-19

Bench: Ms. Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita No.343 & 344/Srt/2025 Assessment Year: (2018-19) Kanchanben Pravinbhai Sheth Vs. Pcit - 1, Surat 3/A, 1 St Floor, Royal Vila Apts., Surat Ghoddod Road, Surat (Jao: Ito, Ward – 1(3)(1), Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Adops2971D (Appellant) (Respondent) Gautam Pravinbhai Sheth (Huf) Vs. Pcit - 1, 3/A, 1 St Floor, Royal Vila Apts., Surat Ghoddod Road, Surat (Jao: Ito, Ward – 1(3)(1), Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aafhg1435A (Appellant) (Respondent) Appellant By Shri Sapnesh Sheth, Advocate Respondent By Ms. Namita Patel, Sr. Dr Date Of Hearing 25/08/2025 Date Of Pronouncement 18/11/2025

Section 10(38)Section 147Section 263

Transfer Pricing Officer, as the case may be, shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner,- (a) the order is passed without making inquiries or verification which should have been made

INCOME TAX OFFICER, WARD-2(3)(8), SURAT vs. MAHAVEER SHANTILAL JAIN, SURAT

ITA 453/SRT/2019[2013-14]Status: DisposedITAT Surat25 Sept 2023AY 2013-14

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.453/Srt/2019 "नधा"रण वष"/Assessment Year: (2013-14) (Physical Hearing) The Ito, Vs. Mahaveer Shantilal Jain, Ward-2(3)(8), Prop. M/S Mukesh Diamonds, 1St Surat. Office No.401, Floor, H.No.5/1171/72/73/1090, New Dtc, Hath Falia, Haripura, Surat – 395009. (Appellant) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aqupj6439L Appellant By Shri Ritesh Mishra, Cit(Dr) Respondent By Shri P. M. Jagasheth, Ca Date Of Hearing 08/09/2023 Date Of Pronouncement 25/09/2023

Section 142(1)Section 143(2)Section 143(3)

exempt, in that event an alternate basis for taxing the income in the hands of the AOP of the contributories is sought to be set up. For the reasons already indicated, the entire exercise is only contingent on a future event and a consequence that may enure upon the decision of the Tribunal, that again if the Tribunal were

SAHADARI KHAND UDYOG MANDAL LTD.,,NA vs. ARIVS.ACIT, NAVSARI CIRCLE, NAVSARI, NAVSARI

ITA 212/SRT/2020[2012-13]Status: DisposedITAT Surat25 Nov 2025AY 2012-13
Section 143(3)Section 37(1)

exempt in the hands of sugarcane growers\nas agricultural income while the assesse society is a pure business\nentity and not a charitable trust.\n(vi) That the appellant could not prove that a higher price was paid by\nit to the farmers on account of higher yield or some other factors.\nBesides nowhere it has been claimed that

SHREE KHEDUT SAHAKARI KHAND UDYOG MANDLI LTD.,BARDOLI vs. INCOME TAX OFFICER, WARD-1, BARDOLI

In the result, all the appeals are disposed of in the manner indicated\nhereinbefore

ITA 738/SRT/2023[2012-13]Status: DisposedITAT Surat25 Nov 2025AY 2012-13
Section 143(3)Section 37(1)

exempt in the hands of sugarcane growers\nas agricultural income while the assesse society is a pure business\nentity and not a charitable trust.\n(vi) That the appellant could not prove that a higher price was paid by\nit to the farmers on account of higher yield or some other factors.\nBesides nowhere it has been claimed that

MAROLI VIBHAG KHAND UDYOG SAHAKARI MANDALI LTD,.,NA vs. ARIVS.ACIT, NAVSARI CIRCLE, , NAVSARI

ITA 17/SRT/2021[2012-13]Status: DisposedITAT Surat25 Nov 2025AY 2012-13
Section 143(3)Section 37(1)

exempt in the hands of sugarcane growers\nas agricultural income while the assesse society is a pure business\nentity and not a charitable trust.\n(vi) That the appellant could not prove that a higher price was paid by\nit to the farmers on account of higher yield or some other factors.\nBesides nowhere it has been claimed that

ACIT, NA vs. ARI CIRCLE, NAVSARIVS.M/S. MAROLI VIBHAG KHAND UDYOG SAHAKARI MANDALI LTD.,, NAVSARI

In the result, all the appeals are disposed of in the manner indicated\nhereinbefore

ITA 225/SRT/2020[2014-15]Status: DisposedITAT Surat25 Nov 2025AY 2014-15
Section 143(3)Section 37(1)

exempt in the hands of sugarcane growers\nas agricultural income while the assesse society is a pure business\nentity and not a charitable trust.\n(vi) That the appellant could not prove that a higher price was paid by\nit to the farmers on account of higher yield or some other factors.\nBesides nowhere it has been claimed that

ACIT, NA vs. ARI CIRCLE, NAVSARIVS.M/S. MAROLI VIBHAG, KAND UDYOG SAHAKARI MANDALI LTD., NAVSARI

In the result, all the appeals are disposed of in the manner indicated\nhereinbefore

ITA 222/SRT/2020[2011-12]Status: DisposedITAT Surat25 Nov 2025AY 2011-12
Section 143(3)Section 37(1)

exempt in the hands of sugarcane growers\nas agricultural income while the assesse society is a pure business\nentity and not a charitable trust.\n(vi) That the appellant could not prove that a higher price was paid by\nit to the farmers on account of higher yield or some other factors.\nBesides nowhere it has been claimed that

SAHAKARI KHAND UDYOG MANDAL LTD.,,GANDEVI vs. ACIT, NAVSARI CIRCLE, NAVSARI, NAVSARI

ITA 211/SRT/2020[2011-12]Status: DisposedITAT Surat25 Nov 2025AY 2011-12
Section 143(3)Section 37(1)

exempt in the hands of sugarcane growers\nas agricultural income while the assesse society is a pure business\nentity and not a charitable trust.\n(vi) That the appellant could not prove that a higher price was paid by\nit to the farmers on account of higher yield or some other factors.\nBesides nowhere it has been claimed that

SAHAKARI KHAND UDUOG MANDAL LTD.,NA vs. ARIVS.DCIT, NAVSARI CIRCLE, NAVSARI, NAVSARI

In the result, all the appeals are disposed of in the manner indicated\nhereinbefore

ITA 213/SRT/2020[2013-14]Status: DisposedITAT Surat25 Nov 2025AY 2013-14
Section 143(3)Section 37(1)

exempt in the hands of sugarcane growers\nas agricultural income while the assesse society is a pure business\nentity and not a charitable trust.\n(vi) That the appellant could not prove that a higher price was paid by\nit to the farmers on account of higher yield or some other factors.\nBesides nowhere it has been claimed that

TARA RAJU PATEL,VALSAD vs. INCOME TAX OFFICER, INTERNATIONAL TAXATION, , SURAT

In the result, the appeal of assessee is allowed

ITA 195/SRT/2023[2012-13]Status: DisposedITAT Surat26 Jun 2023AY 2012-13

Bench: Shri Pawan Singh(Virtual Hearing) Raju Maganlal Patel, I.T.O. C/O-Dinkarbhai T. Patel, Shankar (International Taxation), Vs. Talao, Via-Dungri, Valsad. Surat. Pan No. Auspp 1436 F Appellant/ Assessee Respondent/ Revenue Tara Raju Patel, I.T.O. C/O-Dinkarbhai T. Patel, Shankar (International Taxation), Vs. Talao, Via-Dungri, Valsad. Surat. Pan No. Avdpp 6714 G Appellant/ Assessee Respondent/ Revenue

Section 133(6)Section 144Section 147Section 148Section 254(1)Section 69

Transfer Pricing), Ahmedabad on 27/03/2018. Notice under Section 148 dated 28/03/2018 was served upon the assessee through speed post. The Assessing Officer recorded that in response to notice under Section 148, no return of income was filed. The Assessing Officer further recorded that despite serving several notices, which was allegedly served, no justification of cash deposit was Raju Maganlal Patel

SHRI RAJU MAGANLAL PATEL,VALSAD vs. INCOME TAX OFFICER, INT. TAXATION, SURAT, SURAT

In the result, the appeal of assessee is allowed

ITA 188/SRT/2023[2011-12]Status: DisposedITAT Surat26 Jun 2023AY 2011-12

Bench: Shri Pawan Singh(Virtual Hearing) Raju Maganlal Patel, I.T.O. C/O-Dinkarbhai T. Patel, Shankar (International Taxation), Vs. Talao, Via-Dungri, Valsad. Surat. Pan No. Auspp 1436 F Appellant/ Assessee Respondent/ Revenue Tara Raju Patel, I.T.O. C/O-Dinkarbhai T. Patel, Shankar (International Taxation), Vs. Talao, Via-Dungri, Valsad. Surat. Pan No. Avdpp 6714 G Appellant/ Assessee Respondent/ Revenue

Section 133(6)Section 144Section 147Section 148Section 254(1)Section 69

Transfer Pricing), Ahmedabad on 27/03/2018. Notice under Section 148 dated 28/03/2018 was served upon the assessee through speed post. The Assessing Officer recorded that in response to notice under Section 148, no return of income was filed. The Assessing Officer further recorded that despite serving several notices, which was allegedly served, no justification of cash deposit was Raju Maganlal Patel

THE DCIT, CIRCLE-1(3), SURAT vs. SMT. URMI NILESH NAGARSETH, SURAT

In the result, the appeal of the revenue is dismissed

ITA 170/AHD/2016[2008-09]Status: DisposedITAT Surat09 Oct 2020AY 2008-09

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Virtual Court) Deputy Commissioner Of Income Vs. Smt Urmi Nilesh Nagarseth, Tax, Circle-1(3), Surat C-4, Dharam Palace, B/H. Sneh Sankul Hall, Anand Mahal Road, Adajan, Surat-395009. Pan : Abrpn1596Q Appellant Respondednt

Section 10Section 10(37)Section 107Section 147Section 148Section 2Section 78

transfer of land registration and paying market price. The contention of assessee was not accepted by A.O. The AO took his view that land in question was not acquired by way of compulsory acquisition, but it was purchased from assessee after negotiating the rate. The AO disallowed exemption

ACIT, NA vs. ARI CIRCLE., NAVSARIVS.M/S. MAROLI VIBHAG KHAND UDYOG SAHAKARI MANDALI LTD,, NAVASARI

ITA 224/SRT/2020[2013-14]Status: DisposedITAT Surat25 Nov 2025AY 2013-14
Section 143(3)Section 37(1)

exempt in the hands of sugarcane growers\nas agricultural income while the assesse society is a pure business\nentity and not a charitable trust.\n(vi) That the appellant could not prove that a higher price was paid by\nit to the farmers on account of higher yield or some other factors.\nBesides nowhere it has been claimed that

DHANSUKHBHAI PARAGJIBHAI PATEL,,SURAT vs. THE DCIT, CIRCLE-2(3),, SURAT

In the result, the appeal of the assessee partly allowed

ITA 1021/AHD/2016[2009-10]Status: DisposedITAT Surat03 Feb 2020AY 2009-10

Bench: Shri Sandeep Gosain & Shri O.P.Meena, Accoutant Member आ.अ.सं/.I.T.A No.1021/Ahd/2016 िनधा"रण वष"/Assessment Year:2009-10 Shri Dhansukhbhai Deputy Commissioner Of Paragjibhai Patel, Income-Tax, 143, Brahaman Faliya, Circle - 2(3) Surat Dindoli Udhna 394210 Pan: Avdpp7007 L अपीलाथ" Appellant ""यथ"/Respondent

Section 10(37)Section 143Section 148Section 77

exemption under section 10(37) is available where the assessee has been carrying on agricultural operation during the period of two years immediately preceding from the date of transfer and the land was acquired under compulsory acquisition. The assessee has filed a letter no. TBT/OUT/ 4089 /22 dated. 23.09.2014 and claimed that agricultural block situated at Dindoli Surat was kept

SHREE NARMADA KHAND UDYOG SAHKARI MANDALI LTD.,NARMADA vs. INCOME TAX OFFICER, WARD - 2(1), BHARUCH

In the result, the grounds of appeal raised by the assesse are allowed

ITA 103/SRT/2023[2013-14]Status: DisposedITAT Surat31 Oct 2023AY 2013-14

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 234ASection 254(1)Section 271(1)(c)Section 28Section 37Section 37(1)

exempt either wholly or partially, any producer of sugar from payment of the additional price due from him under sub-clause (1) in respect of sugarcane purchased for that factory during that year. (4) The Central Government may appoint any person or authority as it thinks fit for the purpose of determining the additional price due from a producer

SHREE NARMADA KHAND UDYOG SAHKARI MANDALI LTD.,NARMADA vs. INCOME TAX OFFICER, WARD - 2(1), BHARUCH

In the result, the grounds of appeal raised by the assesse are allowed

ITA 102/SRT/2023[2012-13]Status: DisposedITAT Surat31 Oct 2023AY 2012-13

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 234ASection 254(1)Section 271(1)(c)Section 28Section 37Section 37(1)

exempt either wholly or partially, any producer of sugar from payment of the additional price due from him under sub-clause (1) in respect of sugarcane purchased for that factory during that year. (4) The Central Government may appoint any person or authority as it thinks fit for the purpose of determining the additional price due from a producer